· 2/23/1915

Meeker & Co. v. Lehigh Valley RR

Citations

236 U.S. 412
35 S. Ct. 328
59 L. Ed. 644
1915 U.S. LEXIS 1771

Syllabus

The limitations in Rev. Stat., § 1047, on suits for penalties accruing under the laws of the United States, relate to punitive penalties for infractions of public law. and not to liabilities imposed for redressing a private injury even though the wrongful act be a public oifense and punishable as such. It does not relate to a liability accruing under §§ 8, 9, 14 and 16 of the Act to Regulate Commerce which is not punitive but strictly remedial. While Congress did not intend, in amending § 16 of the Act to Regulate Commerce by the act of July 29, 1906, to.reserve claims already barred by local statutes, it did intend to take all other claims out of the operation of the varying state laws and subject them to limitations of its own creation operating alike in all the States. The effect of the amendment to § 16 of the Act to Regulate Commerce by the act of July 29, 1906, was to extend the time for invoking action by the Commission upon complaints for damages to two years from the accrual of the claim, but until one year after the passage of the act as to all claims which had accrued before its passage. The purpose of the joint resolution of June 30, 19Ó6, postponing the effective date of the act of June 29, 1906, amending the Act to Regulate Commerce, was to cause the act to speak and operate at the end of the postponed period as if that were the time of its passage, and when the extended period expired it gave a full year for presenting accrued claims. Objections to portions of the reports of the Interstate Commerce Commission awarding reparation for which the action is brought, on the ground that they contain statements which are not findings of fact, and not definitely identified in the record, are waived by failure to direct the court to the subject when charging the jury. Under § 16 of the Act to Regulate Commerce, as amended by the act of June 29,1906, the report of the Commission awarding reparation need not necessarily state

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

holding that the words \penalty or forfeiture\ in federal statute \refer to something imposed in a punitive way for an infraction of a public law\ (emphasis added)
stating that prima facie evidence “only establishes a rebuttable presumption.”
stating that use of the phrase “prima facie evidence” in a statute “only establishes a rebuttable presumption,” and “cuts off no defense, interposes no obstacle to a full contestation of all the issues, and takes no question of fact from either court or jury.”
a penalty covered by the predecessor to §2462 is “something imposed in a punitive way for an infraction of a public law”
Interstate Commerce Act provision that findings of I.C.C. were admissible as prima facie evidence of facts recited therein in a suit to enforce a reparation award was not violative of the seventh amendment
“Sanctions imposed for the purpose of deterring infractions of public laws are inherently punitive[.]”

Source: CourtListener parenthetical corpus (CC0).

Judges: Van Devanter

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