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Houston, East & West Texas Railway Co. v. United States (The Shreveport Rate Cases)

United States Supreme Court
234 U.S. 342 (1914)


Facts

The Houston, East & West Texas Railway Co. (the railway) (plaintiff) functioned to facilitate commerce among Texas cities and between Texas and Shreveport, Louisiana. However, the railway charged significantly higher rates for the transportation of goods from Shreveport to Texas cities than from Dallas and Houston to those same Texas cities. The result of this was to severely impair commerce from Shreveport. The Interstate Commerce Commission, established by Congress (defendant), sought to regulate this situation by fixing the maximum price that could be charged by the railway on its interstate routes to be comparable to its intrastate routes. The railway brought suit in the Commerce Court, arguing that because the Interstate Commerce Commission was setting the price of interstate commerce based on its determination of what was reasonable in intrastate commerce, it was overstepping its Congressional authority to regulate interstate commerce. The Commerce Court rejected this argument and held that the Interstate Commerce Commission acted constitutionally. The railway appealed.

Rule of Law

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Issue

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Holding and Reasoning (Hughes, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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