Chicago v. Atchison, T. & S. F. R. Co.
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| Chicago v. Atchison T. & S.F. Ry. Co. | |
| Reference: 357 US 77 (1958) | |
| Term: 1957-1958 | |
| Important Dates | |
| Argued: March 4 - 5, 1958 Decided: June 16, 1958 | |
| Outcome | |
| United States Court of Appeals for the 7th Circuit affirmed | |
| Majority | |
| Chief Justice Earl Warren • Hugo Black • William O. Douglas • Tom Clark • William Brennan • Charles Evans Whittaker | |
| Dissenting | |
| Felix Frankfurter • Harold Burton • John Harlan II | |
City of Chicago v. Atchison, Topeka & Santa Fe Railway Company (Chicago v. Atchison, T. & S.F. Ry. Co.) is a case decided on June 16, 1958, by the United States Supreme Court that broadened the class of parties who could receive standing to contest administrative actions under the Administrative Procedure Act (APA) to include those who had suffered an economic injury. The case concerned a municipal ordinance approved by the City of Chicago that aimed to regulate the operation of a motor carrier transfer service that shuttled passengers between train terminals in the city. The United States Supreme Court granted standing to a motor carrier service involved in the dispute—enlarging the scope of eligibility to receive standing in administrative challenges to include parties who had suffered economic harm.[1][2]
Why it matters: The United States Supreme Court granted standing to the motor carrier service involved in the case by interpreting a "legal wrong" as an economic injury. The court's interpretation increased the class of parties who could receive standing to contest administrative actions under the APA to include those who had suffered economic harm. The court also held that municipal governments could not regulate the local operation of interstate commerce.[3]
Background
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Railroad operators in the City of Chicago had jointly contracted with Parmelee Transportation Company, a motor carrier service, to transfer passengers between train terminals in the city. The railroad operators terminated their contract with Parmelee Transportation Company in 1955 and entered into a new agreement with Railroad Transfer Service to provide the same service. The city subsequently passed a municipal ordinance requiring the new motor carrier service to obtain a certificate of convenience and necessity from the Commissioner of Licenses as well as the approval of the city council before it could legally transfer passengers. Railroad Transfer Service refused to apply for the certificate and sued the City of Chicago in federal district court on the grounds that the municipal ordinance was invalid. Parmelee Transportation Company, which was excepted from the new ordinance because it had an existing license, joined in the lawsuit as a defendant.[1]
The City of Chicago moved for summary judgment and the district court dismissed the case on the grounds that it did not concern any genuine issues of fact. The United States Court of Appeals for the 7th Circuit reversed the ruling and held that the municipal ordinance was unconstitutional since it attempted to regulate interstate railroad transportation, which is subject to federal regulation under the Interstate Commerce Act. The City of Chicago filed a petition of certiorari with the United States Supreme Court.[1]
The court granted certiorari to the City of Chicago but postponed hearing the appeal from Parmelee Transportation Company until it determined whether or not the company had standing to seek review of the case. The Supreme Court decided that Parmelee Transportation Company had standing because the company had "a direct and substantial personal interest in the outcome" and sought relief from what it considered to be economic injury through unlawful competition from Railroad Transfer Service.[1]
Oral argument
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Oral arguments were held on March 4-5, 1958. The case was decided on June 16, 1958.[1]
Decision
The United States Supreme Court affirmed the lower court's ruling in a 6-3 decision. The majority opinion was written by Justice Hugo Black and joined by Chief Justice Earl Warren and Justices William O. Douglas, Tom Clark, William Brennan, and Charles Evans Whittaker. Justice John Harlan II issued a dissenting opinion joined by Justices Felix Frankfurter and Harold Burton.[1]
Opinions
Opinion of the court
Writing for the majority, Justice Hugo Black argued that the transfer of passengers between train terminals constituted railroad transportation and, therefore, was subject to federal regulation under the Interstate Commerce Act. Black contended that the City of Chicago's ordinance impeded the continuity of federal regulation of interstate transportation:[1]
| “ | National, rather local, control of interstate railroad transportation has long been the policy of Congress. It is not at all extraordinary that Congress should extend freedom from local restraints to the movement of interstate traffic between railroad terminals. Serious impediments to the efficient and uninterrupted flow of this traffic might well result if the City could deny the railroads the right to transfer passengers by their own vehicles or by those of their selected agents. ... The railroads have rejected as unsuitable the only transfer service now licensed to operate by the City. If local officials can prevent them from providing this service by some other means a breakdown in the organized transfer of passengers could result. At a minimum, they would be forced to deal once again with the rejected operator. Moreover, it seems clear that, if the City could deny a license to one operator, it has the power, at least so far as the Interstate Commerce Act is concerned, to deny a license to all.[4] | ” |
| —Justice Hugo Black, majority opinion in Chicago v. Atchison T. & S.F. Ry. Co. (1958)[1] | ||
Dissenting opinion
Justice John Harlan II authored a dissenting opinion joined by Justices Felix Frankfurter and Harold Burton. The justices argued that that the Supreme Court could not determine whether or not the municipal ordinance trespassed on federal authority until Railroad Transfer Service had completed the application process for a certificate of convenience and necessity. Moreover, the justices claimed that the Interstate Commerce Act could not prevent the City of Chicago from enacting local regulations to govern its roads "because there may be some incidental, but not burdensome, effect on interstate commerce."[1]
Impact
The case broadened the class of parties who could receive standing to contest administrative actions pursuant to the APA. Under the APA, an individual "suffering a legal wrong from agency action, or adversely affected of aggrieved by agency action contesting administrative action within the meaning of a relevant statute, is entitled to judicial review thereof." In Chicago v. Atchison T. & S.F. Ry. Co., a "legal wrong" was interpreted to include those who had suffered an economic injury.[3]
See also
- Administrative Procedure Act
- Supreme Court of the United States
- Ballotpedia's administrative state coverage
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 JUSTIA, "Chicago v. Atchison T. & S.F. Ry. Co., 357 U.S. 77 (1958)," accessed June 20, 2018
- ↑ Oyez, "City of Chicago v. Atchison, Topeka & Santa Fe Railway Company," accessed June 20, 2018
- ↑ 3.0 3.1 United States Senate. (2014). Constitution Of The United States Of America: Analysis & Interpretation. Washington, D.C.: Government Printing Office. (pages 754-746).
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
