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New York Central & Hudson River Railroad Co. v. United States

United States Supreme Court
212 U.S. 481 (1909)


Facts

New York Central & Hudson River Railroad Company (New York Central) (defendant) was an entity bound by the federal Elkins Act (the Act) which forbade common carriers such as railroads from charging rates less than their posted rate. New York Central and one of its employees were convicted for paying rebates to certain companies who shipped their products using New York Central, thereby lowering their shipping rate in violation of the Act. New York Central appealed, arguing that parts of the Act were unconstitutional and more specifically, that Congress lacked authority to impute to a corporation the commission of criminal offenses or to subject a corporation to criminal prosecution.

Rule of Law

The rule of law is the black letter law upon which the court rested its decision.

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Issue

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Holding and Reasoning (Day, 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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