Charles River Bridge v. Warren Bridge

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1837 United States Supreme Court case

Charles River Bridge v. Warren Bridge, 36 U.S. (11 Pet.) 420 (1837), was a case regarding the Charles River Bridge and the Warren Bridge of Boston , Massachusetts , heard by the United States Supreme Court under the leadership of Chief Justice Roger B. Taney .

In 1785, the Charles River Bridge Company was granted a charter to construct a bridge over the Charles River connecting Boston and Charlestown , roughly where the present-day Charlestown Bridge is located. When the Commonwealth of Massachusetts sanctioned another company to build the Warren Bridge in 1828, that would be very close in proximity to the first bridge and would connect the same two cities, the proprietors of the Charles River Bridge claimed that the Massachusetts legislature had broken its contract with the Charles River Bridge Company, and thus the contract clause had been violated. The owners of the first bridge claimed that the charter had implied exclusive rights to the Charles River Bridge Company. The Court ultimately sided with Warren Bridge. This decision was received with mixed opinions, and had some impact on the remainder of Taney's tenure as Chief Justice.

Charles River Bridge

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In 1640 the legislature of the Massachusetts Bay Colony , in accordance with common law , assumed control over public ferries . The legislature proceeded to give Harvard College permission to run a ferry on the Charles River between Boston and Charlestown. Harvard operated the ferry until 1785. That year, a group of men petitioned the state legislature to build a bridge across the river due to the inconvenience of the ferry. As time had passed, the two towns had grown and communication between them had become more important, and technology was at a point now where a bridge appeared to be a wise economic undertaking.

The request was granted and the Charles River Bridge Company was given permission to build a bridge and collect tolls for 40 years, but during those 40 years the company would have to pay 200 pounds (or ~$670) to Harvard College annually in order to make up for the profits the college would lose from the ferry. After 40 years of collecting tolls, the company would turn the bridge over to the state, but the government would still have to make the annual payment. In 1792, the Massachusetts legislature extended this charter to seventy years from the opening of the bridge.

Warren Bridge

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Warren Bridge (highlighted) and its competitor (1838)

As time passed, the population of Boston increased, as did the amount of business the city was doing with the rest of the world. With these increases, the Charles River Bridge collected more and more profits, and the value of the company's stock started to rise. Shares that had a par value of $333.33 sold for $1,650 in 1805, and by 1814, their price had risen to $2,080. By 1823, the value of the company was estimated to be $280,000, a substantial increase from its original value of $50,000. Between 1786 and 1827 the Charles River Bridge had collected $824,798 in tolls. Very few of the shares belonged to the company's original investors at this time, and the stock was now owned by men who had bought it at very high prices. The public started to complain about having to continue to pay tolls after the bridge's profits had far surpassed the original capital, with interest; but the new investors did not care. In their opinion, they had paid a large sum for the bridge stock, and they did not wish to stop collecting tolls until they themselves had turned a profit. These proprietors decided not to meet any of the public's demands, and they refused both to improve services and reduce tolls.

There were multiple attempts to convince the state legislature to give permission to build a new bridge between Boston and Charlestown, which would be in direct competition with the Charles River Bridge. Eventually, the legislature agreed to grant a charter for a new bridge between Charlestown and Boston. In 1828, a company was given the rights to build the Warren Bridge , 275 yards from the first one. The Warren Bridge would be turned over to the state once enough tolls had been collected to pay for the bridge's construction, or after a maximum of 6 years, after which it would be free to the public. Since it was free, and so close to the Charles River Bridge, the Warren Bridge would obviously take all of the competing bridge's traffic, and therefore its construction would leave the stock of the Charles River Bridge highly devalued and the shareholders would stand to lose a great deal of money. The owners of the Charles River Bridge appealed to the legislature, which responded by giving them another 30 years to collect tolls, extending the collection period to 100 years.

Arguing the case

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After the Warren Bridge charter was granted, the Charles River Bridge Company filed a lawsuit in the Massachusetts Supreme Judicial Court (SJC) in an effort to stop the construction of the second bridge. The SJC was divided 2–2 on the matter, and the case was appealed to the United States Supreme Court . The case was argued before the Court in 1831, where the plaintiffs argued that it was unconstitutional for the Massachusetts legislature to charter the Warren Bridge, because creating a competing bridge violated the contract clause in Article I, Section 10, which states, "No State shall pass any Bill of Attainder , ex post facto Law, or Law impairing the Obligation of Contracts".

It appears as though Chief Justice John Marshall , Justice Joseph Story and Justice Smith Thompson , were all in agreement that the Massachusetts legislature had indeed violated the obligation of contract clause in the constitution, but because of justice absences, and disagreements between the justices, no final decision was reached, and the case languished for six years. During that time, three new justices were appointed by President Andrew Jackson , including the new Chief Justice, Roger Taney ; the Warren Bridge had been constructed, and made back the money it had cost to build, and had become a toll-free bridge. The Charles River Bridge was now closed, since it was no longer getting any traffic due to its toll.

Before the Charles River Bridge case was argued before the Supreme Court again, there was a situation in 1833 involving the Camden and Amboy Railroad and the Delaware and Raritan Canal companies. This was not a case that went before the Supreme Court, but many prominent lawyers and justices were asked for their opinion on the situation, and among them was Taney, who was then the Attorney General of the United States . Both of the companies had convinced the New Jersey legislature of 1832 to add a condition to their charters that no other companies would be able to build a means of transportation between Philadelphia and New York City for a certain amount of time. Taney's opinion on the case was that no legislature should have the power to stop the state from creating internal improvements because it was such an important aspect of the state's power.

Rearguing the case

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The case of Charles River Bridge v. Warren Bridge began again, on January 19, 1837. Warren Dutton and Daniel Webster represented the Charles River Bridge Company; Simon Greenleaf , a Harvard Law School professor, and John Davis , a senator and former governor from Massachusetts, represented Warren Bridge Company.

The lawyers defending the Warren Bridge said that exclusive rights were not mentioned in the charter. The Charles River Bridge lawyers c

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