Charles River Bridge v. Warren Bridge

In 1650, the Massachusetts legislature granted Harvard College the authority to operate a for-profit ferry between Charlestown and Boston. In 1785, the legislature passed an act incorporating The Proprietors of the Charles River Bridge (PCRB) (plaintiff) to replace the ferry with a bridge over the Charles River. The legislature granted PCRB a 40-year charter to receive tolls, with the agreement that the bridge would become state property at the end of 40 years. The bridge became operational in 1786. In 1792, the legislature extended the charter to 72 years. In 1828, the legislature incorporated The Proprietors of the Warren Bridge (defendants) to build another bridge over the Charles River. The distance between the Charles and Warren bridges was between 264 and 825 feet. The charter provided that the Warren bridge would become state property within six years from the commencement of toll collection. The PCRB sought an injunction to prevent the Warren bridge’s construction, claiming that the bridge unconstitutionally impaired PCRB’s contract with the state. Upon the Warren bridge’s construction, the PCRB filed a supplemental bill claiming lost profits. The Massachusetts Supreme Judicial Court dismissed the bill. The United States Supreme Court heard the case, by which time the Warren bridge had become state property and operated toll-free. The PCRB claimed that: (1) the PCRB had a vested right to operate the Charles River bridge, because Harvard’s exclusive right to operate the ferry on a specific line of travel had transferred to the PCRB; and (2) the 1785 and 1792 acts implied that the legislature would not operate another bridge on the same line of travel, and the legislature’s grants of the ferry and the Charles River bridge were contracts that were impaired by the Warren bridge.