St. Louis & San Francisco Railway Co. v. Gill

Citations

• 156 U.S. 649
• 15 S. Ct. 484
• 39 L. Ed. 567
• 1895 U.S. LEXIS 2170

Syllabus

<p>A special statutory exemption or privilege (such as immunity from taxation or a right to iix and determine rates of fare) does not accompany the property of a railroad company in its transfer to a purchaser, iu the absence of an express direction in the statute to that effect.</p> <p>When á state legislature establishes a tariff of railroad rates so unreasonable as to practically destroy the value of the property of companies engaged in the carrying business, courts of the United States may treat it as a judicial question, and hold such legislation to be in conflict with the Constitution of the United States, as depriving the company of its property without due process of law,- and as depriving it of the equal protection, of the laws.</p> <p>Railroad Commission Cases, 116 U. S. 307; Dow v. Beidelman, 125 U. S. 681; Chicago, Milwaukee &c. Railway v. Minnesota, 134 U. S. 418; Chicago & Grand Trunk Railway v. Wellman, 143 U. S. 339; and Reagan v. Farmers' Loan & Trust Co., 154 U. S. 362, examined in detail.</p> <p>When, by legislation and consolidation, a railroad which was originally all in one State becomes consolidated with other roads in other States, and the State originally incorporating it enacts laws to regulate the rates of the consolidated road within its ‘borders, the proper test as to the reasonableness of these rates is as to their effect upon the consolidated line as a whole.</p> <p>When a State prescribes rates for a railroad, only a part of which is within its borders, the company may raise the question of their reasonableness by way of defence to an action for the recovery of penalties for violating the directions.</p>