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New York Central & Hudson River Railroad Co. v. United States
United States Supreme Court
212 U.S. 481 (1909)
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
Holding and Reasoning (Day, J.)
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