Southern Railway Co. v. Railroad Commission of Indiana

Citations

• 236 U.S. 439
• 35 S. Ct. 304
• 59 L. Ed. 661
• 1915 U.S. LEXIS 1773

Syllabus

<p>If the car is moving on a railroad engaged in interstate commerce it is subject to the provisions and penalties of the Safety Appliance Act, although engaged at the time in intrastate commerce. United States v. Southern Ry., 222 U. S. 20.</p> <p>The principle that an act may constitute a criminal, offense against two sovereignties so that punishment by one does not prevent punishment by the other, only relates to cases where both sovereignties have jurisdiction over the act. It has no application where one of the governments has exclusive jurisdiction of the subject-matter and therefore has the exclusive power to punish.</p> <p>Under the Federal Constitution the power of Congress to regulate interstate commerce is such that when exercised it is exclusive and ipso facto supersedes existing state legislation on the same subject.</p> <p>Congress may so circumscribe its regulations in regard to a matter within its exclusive jurisdiction as to occupy only a limited field and leave a part of the subject open to incidental legislation by the States; but the Safety Appliance Act extended to the whole subject of equipping cars with safety appliances to the exclusion of further action by the States.</p> <p>The Indiana statute requiring railway companies to place grab-irons and hand-holds on the sides and ends of every car having been superseded by the Federal Safety Appliance Act, penalties imposed by the former cannot be recovered as to cars operated on interstate railroads although engaged only in intrastate traffic.</p>