Proprietors of Charles River Bridge v. Proprietors of Warren Bridge
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| Proprietors of Charles River Bridge v. Proprietors of Warren Bridge | |
| Reference: 36 U.S. 420 | |
| Term: 1837 | |
| Important Dates | |
| Argued: Mar 8-11, 1831 Reargued: Jan 19-26, 1837 Decided: Feb 14, 1837 | |
| Majority | |
| Roger Taney | |
| Concurring | |
| John McLean • Philip Pendelton Barbour • Henry Baldwin • James Moore Wayne | |
| Dissenting | |
| Joseph Story • Smith Thompson | |
Proprietors of Charles River Bridge v. Proprietors of Warren Bridge was a case decided on February 14, 1837, and was one of the first decisions in favor of the state in challenges invoking the U.S. Constitution's contract clause. The United States Supreme Court held that the state of Massachusetts did not grant the Charles River Bridge Company exclusive rights to the Charles River and that the state did not violate the previous contract, nor the contract clause of the United States Constitution when it gave another company a contract to build another bridge over the same waters.[1]
Why it matters: Charles River Bridge was one of the first decisions in favor of the state in challenges invoking the U.S. Constitution's contract clause. For more information on the legacy of the Charles River Bridge click here[1]
Background
The Massachusetts legislature in 1785 passed a law granting a charter to the Charles River Bridge Company authorizing the company to build and operate a bridge across the Charles River. The bridge connected the cities of Cambridge and Boston. The proprietors of the Charles River Bridge Company were granted the right to collect tolls for the duration of the charter. The bridge was successfully built and profitable for the stockholders of the company.
The company became less popular in the 1820s due to high tolls high and high profit margins, according to PBS. As the population increased, members of the public asked the state government for more bridges in order to create competition. The state legislature responded in 1828 by granting the Warren Bridge Company a charter to construct a second, toll-free, bridge.[2]
In state court
The Charles River Bridge Company filed suit before the Massachusetts Supreme Judicial Court and argued that the new state-issued charter to the Warren Bridge Company violated its property rights granted by the 1785 charter. The company's attorneys argued that the state act chartering the Warren Bridge violated the contract clause of the U.S. Constitution, which prohibits states from passing laws impairing contract obligations. Charles River Bridge Company cited John Marshall's opinion in Dartmouth College v. Woodward to argue that corporate charters were contracts within the meaning of the contract clause. The Massachusetts Supreme Court was divided 2-2 and the Charles River Bridge Company appealed to the U.S. Supreme Court.[2]
Oral argument
Oral argument was first held from March 8 through 11, 1831. The case was reargued from January 19-26, 1837.[1]
The Supreme Court issued a 5-2 decision on February 14, 1837.[1]
First appearance before the U.S. Supreme Court
The case was argued before the U.S. Supreme Court in 1831. The plaintiffs argued that it was unconstitutional for the Massachusetts General Assembly to charter the Warren Bridge because creating a competitive bridge violated the Charles River Bridge Company's previous contract with the state and thus also violated the contract clause of the U.S. Constitution. The plaintiffs argued that the new state law chartering the Warren Bridge was impaired the obligation of contracts.[3]
The U.S. Supreme Court did not issue an opinion in 1831 because of absences and disagreements among the justices. The case went undecided for six years. During that time, President Andrew Jackson (D) appointed three new justices to the court.[2]
During those six years, the Charles River Bridge closed because it was getting little traffic due to competition from the Warren Bridge.[3]
Second appearance before the U.S. Supreme Court
The U.S. Supreme Court again heard oral arguments beginning on January 19, 1837. The lawyers defending the Warren Bridge Company argued that the original contract with the Charles River Bridge Company was not exclusive. The lawyers defending Charles River Bridge argued the U.S. Supreme Court's primary duty was to protect the property of its citizens, and that allowing the Warren Bridge Company a second contract deprived the Charles River Bridge Company of its property according to the original contract.[3]
Decision
The Supreme Court ruled 5-2 that the state of Massachusetts had not entered into an exclusive contract with the Charles River Bridge Company and therefore did not violate its when it contracted with the Warren Bridge Company to construct a second bridge.[1]
Justice Roger Taney delivered the majority opinion and was joined by John McLean, Philip Pendelton Barbour, Henry Baldwin, James Moore Wayne
Justice John McLean wrote a concurring opinion and was joined by Justices Philip Pendleton Barbour, Henry Baldwin, and James Moore Wayne.
Justice Joseph Story wrote a dissenting opinion and was joined by Smith Thompson.[3]
Opinion
Majority opinion
The Supreme Court held that the state had not entered into an exclusive contract with the Charles River Bridge Company such that they would have exclusive control over the waters of the river. In his majority opinion, Justice Taney weighed property rights, contract law, public need, and community interest and ruled that the community's interest in creating new channels of travel and trade took priority over the Charles River Bridge Company's claim that their property rights had been violated by Warren Bridge Company's contract to operate upon the river. Justice Roger Taney, writing for the 5-2 Supreme Court, argued that the case was strictly about the interpretation of the contract and that the charter contract should be interpreted narrowly, which meant that the Charles River Bridge did not have exclusive rights under the original contract. Taney argued that public grants should be interpreted closely and if there is any uncertainty in the legal document, the court should favor the interpretation that is most beneficial to the public. Taney wrote "While the rights of private property are sacredly guarded, we must not forget that the community also has rights and that the happiness and well-being of every citizen depends on their faithful preservation."[3]
Justice Taney also discussed the negative effects that would ensue if the court sided with the Charles River Bridge Company. He argued that such a precedent would harm travel and transportation throughout the country. Because such a precedent would harm interstate commerce and transportation, Taney argued that the U.S. Supreme Court did not act outside its constitutional role nor violate the principle of federalism by issuing a ruling. Taney argued that canals and railroads were taking away business from highways, and if charters granted monopolies to corporations, these internal improvement projects would fail. Taney said that the country would "be thrown back to the improvements of the last century, and obliged to stand still."[3]
Concurring opinion
Justice John McLean wrote a concurring opinion and was joined by Justices Barbour, Baldwin, and Wayne. In his opinion, he stated that he was in favor of the Charles River Bridge Company but that it was not within the Supreme Court's jurisdiction to make a decision. Justice McLean argued that the ruling in the case violated the principle of federalism because the dispute occurred within a state and that the U.S. Supreme Court did not concern itself with state matters.[3]
Dissenting opinion
Justice Joseph Story wrote a dissenting opinion and was joined by Justice Smith Thompson. In his dissent, Justice Story focussed primarily on federalism and the Supreme Court's authority to rule in the case. Justice Story argued that the Supreme Court violated the principle of federalism by ruling in this case, and that it did not fall within the jurisdiction of the U.S. Supreme Court:
| “ | The only question, over which this court possesses jurisdiction in this case (it being an appeal from a state court and not from the circuit court) is, as has been stated at the bar, whether the obligation of any contract, within the true intent and meaning of the constitution of the United States, has been violated, as set forth in the bill. All the other points argued, are before us only as they are preliminaries and incidents to this. | ” |
Justice Story argued that, in his view, Taney was wrong and that the majority's decision would halt internal improvements:
| “ | For my own part, I can conceive of no surer plan to arrest all public improvements, founded on private capital and enterprise, than to make the outlay of that capital uncertain and questionable, both as to security and as to productiveness. No man will hazard his capital in any enterprise, in which, if there be a loss, it must be borne exclusively by himself; and if there be success, he has not the slightest security of enjoying the rewards of that success, for a single moment. If the government means to invite its citizens to enlarge the public comforts and conveniences, to establish bridges, turnpikes, or canals, or railroads, there must be some pledge, that the property will be safe; that the enjoyment will be co-extensive with the grant; and that success will not be the signal of a general combination to overthrow its rights and to take away its profits. The very agitation of a question of this sort is sufficient to alarm every stockholder in every public enterprise of this sort, throughout the whole country. | ” |
Legacy
The decision in Charles River Bridge was debated along partisan lines. Democrats were generally in favor of the decision and argued that it was a victory for states' rights and limited government. A newspaper run by the Democratic Party wrote of Taney's majority opinion that "he pursues his unbroken chain of clear, logical reasoning, spreads light all around, leaving no cloud to confound or mislead those who may come after him."[5]
Members of the Whig party generally disapproved of Taney's decision and argued that the Massachusetts legislature had erred in creating a contract with the Charles River Bridge Company and that it was not within the Supreme Court's jurisdiction to solve policy disputes at the state level. James Kent wrote for the Whig newspaper, The New York Review, "A gathering gloom is cast over the future. We seem to have sunk suddenly below the horizon, to have lost the light of the sun."[5] In a letter to Justice Joseph Story, Kent wrote, "The court has fallen from its high station and commanding dignity and has lost its energy, and spirit of independence, and accuracy, and surrendered up to the spirit of the day, the true principles of the Constitution."[5]
See also
- Federalism
- Separation of powers
- The Taney Court
- Supreme Court of the United States
- History of the Supreme Court
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 Oyez, Charles River Bridge v. Warren River Bridge, accessed August 24, 2022
- ↑ 2.0 2.1 2.2 Thirteen, Antebellum Landmarks, accessed August 25, 2022
- ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 Justia, Charles River Bridge vs. Warren Bridge, accessed August 24,2022
- ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ 5.0 5.1 5.2 The US Democratic Review, Vol. 7, The Supreme Court of the United States,accessed August 25, 2022
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