West River Bridge Co. v. Dix
West River Bridge Co. v. Dix is a significant Supreme Court case concerning the intersection of state contracts and the exercise of eminent domain. The case arose when the state of Vermont attempted to construct a free road over a toll bridge owned by the West River Bridge Company, which had a one-hundred-year contract with the state. The bridge company argued that the state's actions violated the Contracts Clause of the Constitution, leading them to enlist the prominent attorney Daniel Webster for representation. Ultimately, in a 7-1 decision, the Supreme Court ruled in favor of the state, asserting that Vermont could not contract away its fundamental police powers, thereby allowing eminent domain to take precedence over the previous agreement. The decision highlighted the complexities of contractual obligations versus governmental authority, with Justice James M. Wayne dissenting and Justice John McKinley abstaining from the case. This ruling has implications for understanding how states navigate contracts in relation to their sovereign powers and public interests.
West River Bridge Co. v. Dix
Date: January 31, 1848
Citation: 47 U.S. 507
Issue: Contracts clause
Significance: The Supreme Court expanded eminent domain to prevail over contracts the state made with private parties and further established that police power cannot be contracted away.
The state of Vermont had signed a one-hundred-year contract with the West River Bridge Company but later decided to build a free road over the toll bridge. Although the state paid the bridge company for its property and franchise, the bridge company hired the famed Daniel Webster to represent it, maintaining that the state’s action violated the contracts clause. By a 7-1 vote, the Supreme Court ruled against the bridge company. In the opinion for the Court, Peter V. Daniel wrote that the state could not contract away its basic police power and that eminent domain prevailed over Vermont’s earlier contract. Justice James M. Wayne dissented, and Justice John McKinley did not participate.