United States v. Interstate Commerce Commission
Encyclopedia
United States v. Interstate Commerce Commission, 337 U.S. 426
(1949) is a decision of the Supreme Court of the United States
addressing several issues, including the judicial standard of one party's inability to sue itself, the ability of the United States government
specifically to sue federally affiliated departments, and the ability of courts to determine legislative intent. While this decision did not have many broad implications, it did offer a more "common-sense" understanding of determining what constitutes a justiciable
controversy.
, it was a common practice of many railroad companies to issue wharfage charges on customers when transporting goods from railroad cars and onto pier
s, or vice versa. At some point during the war, the United States government (referred to by the Court in its decision as the "Government") took over operating control of a number of piers in Norfolk, Virginia
. Instead of using the railroad companies' wharfage services, the Government transferred its cargo to and from piers using its own materials. The Government, not requiring any railroad services apart from transporting the goods to and from the site, requested that it be granted an allowance for the wharfage fees, effectively asking for a refund of fees already paid before the request was made. The railroads refused to make this allowance, prompting the Government to request that the railroads then perform the services themselves, a request which the railroads also denied.
The Government, in turn, filed a complaint with the Interstate Commerce Commission
(ICC) against the railroads. In this complaint, the Government argued that, because the railroads had not performed the service that usually called for the wharfage fees, it was, "unjust, unreasonable, discriminatory, [and] excessive" for the railroads to exact payment. The complaint went on to request that the ICC declare the railroads' actions as unlawful (claiming that they violated the Interstate Commerce Act ("Act")), and to award the Government damages for the illegal exaction of wharfage fees. The ICC found that the fees imposed upon the Government were not unreasonable or in violation of the Act. The ICC denied reparations and dismissed the Government's complaint.
After the ICC's decision, the United States government sought relief in United States District Court for the District of Columbia
to have the decision rescinded. In this complaint, the U.S. Government argued that the ICC's decision was capricious, arbitrary, and based on a misapplication of law. Language in the 28 U.S.C.
46 required that any judicial action taken to set aside a decision of the ICC "shall be brought... against the United States," which effectively meant that the United States was bringing suit against itself. As such, the District Court required the Attorney General to appear in court as both plaintiff and defendant on behalf of the Government. The District Court dismissed the case without addressing the matter in contention, basing their decision on the common law
standard that one party cannot bring suit against itself; accordingly, they reasoned, the United States could not bring suit against the United States.
first had to address the concerns raised by the District Court that prompted them to dismiss the Government's suit. Namely, it appeared that the lawsuit, as necessarily constructed by statute, caused the United States to sue itself. Similarly, the Court addressed the argument made by the railroads that, because the Act specified the United States as the defendant in this sort of case, Congress crafted the Act with the intention of preventing the Government from challenging the ICC's orders.
Another facet of the suit that the Court addressed was the defendant's argument that the decision made by the ICC was not subject to judicial review
. For precedent, the defendant cited part 9 of the Interstate Commerce Act (49 U.S.C. 9) which states, in short, that a party pursuing damages against a common carrier
has the choice of bringing action against said carrier with the ICC or in any U.S. district court of "competent jurisdiction." Because the Government had already pursued relief with the ICC, it was argued that the avenue of judicial review was closed.
The final two points that the Court addressed were that of court composition and the ability for the case to be heard on its merits. Specifically, the Court decided on whether the district court hearing this case should be composed of three judges or just one, whether a decision of such court could be appealed directly to the Supreme Court, and if, in fact, the district court could hear and decide on the case based on issues of merit rather than issues of standing.
, joined by Chief Justice Fred M. Vinson
and Associate Justices Reed
, Douglas
, Murphy
, and Rutledge delivered the opinion of the Court. In brief, the Court ruled that the District Court's decision to dismiss the Government's complaint was improper, and ordered the dismissal reversed, remanding the complaint back to the lower court for a hearing based on the case's merits.
In the matter of whether this case, at one point referred to as "United States v. United States, et al.," was a violation of the long-standing theory that a group cannot sue itself, the Court declared that the line of reasoning presented was improper. The Court stated that the defendant's position relied too heavily on mere nomenclature rather than the facts of the case at hand. The opinion presents an analogy for comparison; John Smith suing himself presents no controversy that a court may rule upon, but this same John Smith might indeed have a valid case to bring against another man also named John Smith. In the present case, the Court determined that the controversies involved are "traditionally justiciable," and that the Government, unless prevented by law, has the same right as any other shipper to seek the protection of the courts. This portion of the defendant's position was judged as untenable.
Regarding the defendant's argument that the language of the Interstate Commerce Act demonstrates a legislative intent to prevent the Government from disobeying decisions made by the Interstate Commerce Commission, the Court held that the defendant was in error. If this argument was to be accepted, the Court reasoned, Congress would have been intentionally forcing the United States (as a shipper) to give up the power of self-protection that is enjoyed by every other shipper. The appearance of the Attorney General on both sides of the case was merely a function of the duties of his position rather than a necessary demonstration of the impossibility of suit.
On the issue of the Government's inability to bring suit in a court after having unsuccessfully made a complaint with the ICC, the Court determined that forbidding judicial review in this manner was "out of harmony with the general legislative pattern of administrative and judicial relationships." The Court stated that the defendant's position on this matter was unacceptable. The opinion remarked that, by this argument, "the order [of the ICC] is final and not reviewable by any court, even though entered arbitrarily, without substantial evidence, and in defiance of law." Such a position was deemed inappropriate, and this argument was rejected.
In the final points, the Court found that a judicial review of the type brought by the Government against the railroads did not require a three-judge panel to make a ruling; rather, a single judge was the most appropriate course. In accordance with the other points the Court adopted, it declared that, because the District Court did not hear the case based on the merits of the complaint, it was appropriate to reverse the decision of the lower court and remand the case back for such judgment.
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...
(1949) is a decision of the Supreme Court of the United States
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...
addressing several issues, including the judicial standard of one party's inability to sue itself, the ability of the United States government
Federal government of the United States
The federal government of the United States is the national government of the constitutional republic of fifty states that is the United States of America. The federal government comprises three distinct branches of government: a legislative, an executive and a judiciary. These branches and...
specifically to sue federally affiliated departments, and the ability of courts to determine legislative intent. While this decision did not have many broad implications, it did offer a more "common-sense" understanding of determining what constitutes a justiciable
Justiciability
Justiciability concerns the limits upon legal issues over which a court can exercise its judicial authority. It includes, but is not limited to, the legal concept of standing, which is used to determine if the party bringing the suit is a party appropriate to establishing whether an actual...
controversy.
Background
During World War IIWorld War II
World War II, or the Second World War , was a global conflict lasting from 1939 to 1945, involving most of the world's nations—including all of the great powers—eventually forming two opposing military alliances: the Allies and the Axis...
, it was a common practice of many railroad companies to issue wharfage charges on customers when transporting goods from railroad cars and onto pier
Pier
A pier is a raised structure, including bridge and building supports and walkways, over water, typically supported by widely spread piles or pillars...
s, or vice versa. At some point during the war, the United States government (referred to by the Court in its decision as the "Government") took over operating control of a number of piers in Norfolk, Virginia
Norfolk, Virginia
Norfolk is an independent city in the Commonwealth of Virginia in the United States. With a population of 242,803 as of the 2010 Census, it is Virginia's second-largest city behind neighboring Virginia Beach....
. Instead of using the railroad companies' wharfage services, the Government transferred its cargo to and from piers using its own materials. The Government, not requiring any railroad services apart from transporting the goods to and from the site, requested that it be granted an allowance for the wharfage fees, effectively asking for a refund of fees already paid before the request was made. The railroads refused to make this allowance, prompting the Government to request that the railroads then perform the services themselves, a request which the railroads also denied.
The Government, in turn, filed a complaint with the Interstate Commerce Commission
Interstate Commerce Commission
The Interstate Commerce Commission was a regulatory body in the United States created by the Interstate Commerce Act of 1887. The agency's original purpose was to regulate railroads to ensure fair rates, to eliminate rate discrimination, and to regulate other aspects of common carriers, including...
(ICC) against the railroads. In this complaint, the Government argued that, because the railroads had not performed the service that usually called for the wharfage fees, it was, "unjust, unreasonable, discriminatory, [and] excessive" for the railroads to exact payment. The complaint went on to request that the ICC declare the railroads' actions as unlawful (claiming that they violated the Interstate Commerce Act ("Act")), and to award the Government damages for the illegal exaction of wharfage fees. The ICC found that the fees imposed upon the Government were not unreasonable or in violation of the Act. The ICC denied reparations and dismissed the Government's complaint.
After the ICC's decision, the United States government sought relief in United States District Court for the District of Columbia
United States District Court for the District of Columbia
The United States District Court for the District of Columbia is a federal district court. Appeals from the District are taken to the United States Court of Appeals for the District of Columbia Circuit The United States District Court for the District of Columbia (in case citations, D.D.C.) is a...
to have the decision rescinded. In this complaint, the U.S. Government argued that the ICC's decision was capricious, arbitrary, and based on a misapplication of law. Language in the 28 U.S.C.
United States Code
The Code of Laws of the United States of America is a compilation and codification of the general and permanent federal laws of the United States...
46 required that any judicial action taken to set aside a decision of the ICC "shall be brought... against the United States," which effectively meant that the United States was bringing suit against itself. As such, the District Court required the Attorney General to appear in court as both plaintiff and defendant on behalf of the Government. The District Court dismissed the case without addressing the matter in contention, basing their decision on the common law
Common law
Common law is law developed by judges through decisions of courts and similar tribunals rather than through legislative statutes or executive branch action...
standard that one party cannot bring suit against itself; accordingly, they reasoned, the United States could not bring suit against the United States.
Issues presented
In addition to the facts of the case proper, the CourtSupreme 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...
first had to address the concerns raised by the District Court that prompted them to dismiss the Government's suit. Namely, it appeared that the lawsuit, as necessarily constructed by statute, caused the United States to sue itself. Similarly, the Court addressed the argument made by the railroads that, because the Act specified the United States as the defendant in this sort of case, Congress crafted the Act with the intention of preventing the Government from challenging the ICC's orders.
Another facet of the suit that the Court addressed was the defendant's argument that the decision made by the ICC was not subject to judicial review
Judicial review
Judicial review is the doctrine under which legislative and executive actions are subject to review by the judiciary. Specific courts with judicial review power must annul the acts of the state when it finds them incompatible with a higher authority...
. For precedent, the defendant cited part 9 of the Interstate Commerce Act (49 U.S.C. 9) which states, in short, that a party pursuing damages against a common carrier
Common carrier
A common carrier in common-law countries is a person or company that transports goods or people for any person or company and that is responsible for any possible loss of the goods during transport...
has the choice of bringing action against said carrier with the ICC or in any U.S. district court of "competent jurisdiction." Because the Government had already pursued relief with the ICC, it was argued that the avenue of judicial review was closed.
The final two points that the Court addressed were that of court composition and the ability for the case to be heard on its merits. Specifically, the Court decided on whether the district court hearing this case should be composed of three judges or just one, whether a decision of such court could be appealed directly to the Supreme Court, and if, in fact, the district court could hear and decide on the case based on issues of merit rather than issues of standing.
Decision
Associate Justice Hugo BlackHugo Black
Hugo Lafayette Black was an American politician and jurist. A member of the Democratic Party, Black represented Alabama in the United States Senate from 1927 to 1937, and served as an Associate Justice of the Supreme Court of the United States from 1937 to 1971. Black was nominated to the Supreme...
, joined by Chief Justice Fred M. Vinson
Fred M. Vinson
Frederick Moore Vinson served the United States in all three branches of government and was the most prominent member of the Vinson political family. In the legislative branch, he was an elected member of the United States House of Representatives from Louisa, Kentucky, for twelve years...
and Associate Justices Reed
Stanley Forman Reed
Stanley Forman Reed was a noted American attorney who served as United States Solicitor General from 1935 to 1938 and as an Associate Justice of the U.S. Supreme Court from 1938 to 1957. He was the last Supreme Court Justice who did not graduate from law school Stanley Forman Reed (December 31,...
, Douglas
William O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
, Murphy
Frank Murphy
William Francis Murphy was a politician and jurist from Michigan. He served as First Assistant U.S. District Attorney, Eastern Michigan District , Recorder's Court Judge, Detroit . Mayor of Detroit , the last Governor-General of the Philippines , U.S...
, and Rutledge delivered the opinion of the Court. In brief, the Court ruled that the District Court's decision to dismiss the Government's complaint was improper, and ordered the dismissal reversed, remanding the complaint back to the lower court for a hearing based on the case's merits.
In the matter of whether this case, at one point referred to as "United States v. United States, et al.," was a violation of the long-standing theory that a group cannot sue itself, the Court declared that the line of reasoning presented was improper. The Court stated that the defendant's position relied too heavily on mere nomenclature rather than the facts of the case at hand. The opinion presents an analogy for comparison; John Smith suing himself presents no controversy that a court may rule upon, but this same John Smith might indeed have a valid case to bring against another man also named John Smith. In the present case, the Court determined that the controversies involved are "traditionally justiciable," and that the Government, unless prevented by law, has the same right as any other shipper to seek the protection of the courts. This portion of the defendant's position was judged as untenable.
Regarding the defendant's argument that the language of the Interstate Commerce Act demonstrates a legislative intent to prevent the Government from disobeying decisions made by the Interstate Commerce Commission, the Court held that the defendant was in error. If this argument was to be accepted, the Court reasoned, Congress would have been intentionally forcing the United States (as a shipper) to give up the power of self-protection that is enjoyed by every other shipper. The appearance of the Attorney General on both sides of the case was merely a function of the duties of his position rather than a necessary demonstration of the impossibility of suit.
On the issue of the Government's inability to bring suit in a court after having unsuccessfully made a complaint with the ICC, the Court determined that forbidding judicial review in this manner was "out of harmony with the general legislative pattern of administrative and judicial relationships." The Court stated that the defendant's position on this matter was unacceptable. The opinion remarked that, by this argument, "the order [of the ICC] is final and not reviewable by any court, even though entered arbitrarily, without substantial evidence, and in defiance of law." Such a position was deemed inappropriate, and this argument was rejected.
In the final points, the Court found that a judicial review of the type brought by the Government against the railroads did not require a three-judge panel to make a ruling; rather, a single judge was the most appropriate course. In accordance with the other points the Court adopted, it declared that, because the District Court did not hear the case based on the merits of the complaint, it was appropriate to reverse the decision of the lower court and remand the case back for such judgment.