1898 United States Supreme Court case
Smyth v. Ames Full case name Smyth, Attorney General, et al. v. Ames, et al.; Smyth, Attorney General, et al. v. Smith, et al.; Smyth, Attorney General, et al. v. Higginson, et al. Citations 171 U.S. 361 (more Voided Nebraska railroad tariffs and defined the constitutional limits of governmental power to set railroad and utility rates. Chief Justice Melville Fuller Associate Justices John M. Harlan · Horace Gray David J. Brewer · Henry B. Brown George Shiras Jr. · Edward D. White Rufus W. Peckham · Joseph McKenna Majority Harlan Fourteenth Amendment to the United States Constitution , Contract Clause Overruled by
Federal Power Commission v. Hope Natural Gas Co. , 320 U.S. 591 (1944)
Smyth v. Ames The Maximum Freight Case Supreme Court case .[ 1] Nebraska railroad tariff law, declaring that it violated the Fourteenth Amendment to the United States Constitution in that it takes property without the due process of law.[ 2] Federal Power Commission v. Hope Natural Gas Company [ 3] [ 4]
The decision in Smyth v. Ames was unanimous and Justice John M. Harlan delivered the opinion of the Court in writing.[ 5]
On April 12, 1893,[ 6] [ 2] Railroad Commissioners of Nebraska were empowered to reduce any freight rate.[ 6]
Several precedents had been set by the Supreme Court regarding state control over railways. Until Munn v. Illinois Granger Laws were declared constitutional, it had been held that railway property was protected from state authority by the Contract Clause of the Constitution, which states that no state shall pass any "Law impairing the Obligation of Contracts". However, in the Munn case, the Court ruled that all property was held subject to legislative regulation if it was "affected with a public interest". Further decisions built off the Munn decision, specifying that while the legislature may regulate property "affected by the public interest", they must exercise it reasonably by applying the used and useful principle , so as to not deprive citizens of their property without due process of law.[ 7]
The maximum rate law was contested by the Union Pacific , St. Joseph and Grand Island Railway , Omaha and Republican Valley Railway , and the Kansas City and Omaha Railway . They claimed the law was confiscation, and therefore unconstitutional.[ 6] $ 2,250,00 annually.[ 8]
The Supreme Court unanimously found the law unconstitutional. The court found that it is not enough to show a tariff – even if the tax is in the public interest – still leaves a company enough money to pay operating expenses and stock dividends.[ 9]
Effects of the decision [ edit ] Businessmen were pleased by the decision, and believed it would give stability to railroad investments.[ 10] [ 11]
The Interstate Commerce Commission was weakened by the Court's decision.[ 12]
The ruling was overturned in the 1944 case of Federal Power Commission v. Hope Natural Gas Co. [ 3] [ 4] Constantine Joseph Smyth , later served as Chief Justice of the Court of Appeals of the District of Columbia .
^ Smyth v. Ames , 171 U.S. 361 (1898).^ a b Public Opinion: A Comprehensive Summary of the Press Throughout the World on All Important Current Topics ^ a b Federal Power Commission v. Hope Natural Gas Co. , 320 U.S. 591 (1944).^ a b Siegel, Stephen A. Smyth v. Ames . Answers.com . Accessed 18 February 2009 ^ "Smyth v. Ames, 169 U.S. 466 (1898)" . Justia Law . Retrieved August 20, 2024 .^ a b c "Nebraska Law Invalid" (PDF) . NYT . March 8, 1898. Retrieved February 18, 2009 .^ "The central law journal" . The Central Law Journal . 46 (24). St. Louis, MO: Soule, Thomas & Wentworth: 489. June 10, 1898. Retrieved February 18, 2009 .^ Colby, Frank Moore (1899). The International Year Book ^ The Nation ^ "Maximum Rate Decision" (PDF) . NYT . March 9, 1898. Retrieved February 18, 2009 .^ Shaw, Albert (1898). Review of Reviews and World's Work: An International Magazine ^ Myers, Gustavus (1912). History of the Supreme Court of the United States
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