Supreme Court CasesSupreme Court Cases

Wabash, St.Louis, & Pacific Wabash, St.Louis, & Pacific Railway Co. v. Illinois (1886)Railway Co. v. Illinois (1886)

BackgroundBackground Long-haul, short-haul Long-haul, short-haul

discrimination by the discrimination by the railroads within the railroads within the state of Illinois state of Illinois (penalties were applied)(penalties were applied)

IssueIssue Could the state regulate Could the state regulate

railroads on the railroads on the intrastate (within a intrastate (within a state)state) portion of an portion of an interstate (between interstate (between states) states) trip?trip?

DecisionDecision State law was State law was

unconstitutionalunconstitutional The power to regulate The power to regulate

interstate commerce interstate commerce belongs to Congressbelongs to Congress

ImportanceImportance Put pressure on Put pressure on

Congress to act if the Congress to act if the states can’t regulate states can’t regulate the railroadsthe railroads

One year after the One year after the decision Congress decision Congress passed the passed the Interstate Interstate Commerce ActCommerce Act

Munn v. Illinois (1877)Munn v. Illinois (1877)

BackgroundBackground State of Illinois had State of Illinois had

passed Granger passed Granger laws to set rates of laws to set rates of railroads and grain railroads and grain elevators (to help elevators (to help farmers)farmers)

IssueIssue Did Illinois law Did Illinois law

deprive railroads of deprive railroads of property (profits) property (profits) without due without due process?process?

DecisionDecision State law State law was was

constitutionalconstitutional because the law because the law was related to the was related to the public interestpublic interest

ImportanceImportance Railroad rates were Railroad rates were

limited by the state limited by the state governmentgovernment

In Re Debs - 1895In Re Debs - 1895 Background:Background:

Eugene V.Debs, Eugene V.Debs, president of the president of the American Railway American Railway Union, led a strike Union, led a strike against the Pullman against the Pullman Railroad which had the Railroad which had the effect of halting the effect of halting the distribution of the U.S. distribution of the U.S. mail. He refused to mail. He refused to honor an injunction to honor an injunction to stop the strike.stop the strike.

Constitutional IssueConstitutional Issue Fifth Amendment due Fifth Amendment due

process rights of Debs process rights of Debs vs Article I Sect VIII vs Article I Sect VIII commerce clause.commerce clause.

DecisionDecision Upheld authority of Upheld authority of

Federal Gov’t to halt Federal Gov’t to halt Pullman RR Car Strike.Pullman RR Car Strike.

Court decided that Court decided that Debs' actions were Debs' actions were illegal because the illegal because the strike also hurt the strike also hurt the public interest when it public interest when it stopped the delivery of stopped the delivery of the mail. the mail.

Importance: Injunction Importance: Injunction became powerful weapon became powerful weapon used by employersused by employers against against strikersstrikers

United States v. E.C. Knight Co. United States v. E.C. Knight Co. (1895)(1895)

BackgroundBackground American Sugar Refining American Sugar Refining

Co. bought stock in Co. bought stock in smaller companies & smaller companies & controlled 90% of sugar controlled 90% of sugar processed in U.S. processed in U.S. (horizontal monopoly) (horizontal monopoly)

IssueIssue Can Congress regulate Can Congress regulate

manufacturing? manufacturing? Can Congress outlaw Can Congress outlaw

“manufacturing “manufacturing monopolies”?monopolies”?

DecisionDecision Federal Gov’t cannot Federal Gov’t cannot

regulate refineries because regulate refineries because they were manufacturing they were manufacturing operations, operations, not directly not directly related to interstate related to interstate commercecommerce

State gov’t. can regulate State gov’t. can regulate local activities under the local activities under the terms of 10terms of 10thth Amendment Amendment (Reserved Powers) (Reserved Powers)

ImportanceImportance Few attempts made to Few attempts made to

prosecute corporations in prosecute corporations in restraint of trade (most restraint of trade (most against unions as against unions as “unreasonable restraint of “unreasonable restraint of trade”)trade”)