Southern R. Co. v. United States
Encyclopedia
Southern Railway Company v. United States, 222 U.S. 20
(1911), was a decision by the United States Supreme Court
which held that under the Commerce Clause
, the U.S. Congress
can regulate safety on intrastate rail traffic because there is a close and substantial connection to interstate traffic.
Congress had required that all train cars be equipped with coupler
s as a safety measure. Southern Railway argued that the requirement only applied to train cars crossing state lines and not train cars that operated inside one state.
is plenary to protect persons and property moving in interstate commerce from all danger. No matter the source or destination, U.S. Congress
may require all vehicles moving on lanes of interstate commerce to be so equipped with safety devices to avoid danger to persons and property moving in interstate commerce.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1911), was a decision by the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
which held that under the Commerce Clause
Commerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
, the U.S. Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
can regulate safety on intrastate rail traffic because there is a close and substantial connection to interstate traffic.
Congress had required that all train cars be equipped with coupler
Coupling (railway)
A coupling is a mechanism for connecting rolling stock in a train. The design of the coupler is standard, and is almost as important as the railway gauge, since flexibility and convenience are maximised if all rolling stock can be coupled together.The equipment that connects the couplings to the...
s as a safety measure. Southern Railway argued that the requirement only applied to train cars crossing state lines and not train cars that operated inside one state.
Facts of the Case
The Safety Appliance Act of March 2, 1893, 27 Stat. 531, c. 196:- ...imposed upon every carrier "engaged in interstate commerce by railroad" the duty of equipping all trains, locomotives, and cars used on its line of railroad in moving interstate traffic, with designated appliances calculated to promote the safety of that traffic...
Holding
The Commerce ClauseCommerce Clause
The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...
is plenary to protect persons and property moving in interstate commerce from all danger. No matter the source or destination, U.S. Congress
United States Congress
The United States Congress is the bicameral legislature of the federal government of the United States, consisting of the Senate and the House of Representatives. The Congress meets in the United States Capitol in Washington, D.C....
may require all vehicles moving on lanes of interstate commerce to be so equipped with safety devices to avoid danger to persons and property moving in interstate commerce.