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Seaboard Air Line Railway v. Blackwell

Supreme Court of the United States · Constitutional Law

Constitutional LawCommerce ClauseState Police PowerCommerce Clauseinterstate commercestate police powerrailroad crossingsdirect burden

Facts

The plaintiff's son was killed when a passenger train struck him at a public grade crossing outside Elberton, Georgia. The complaint alleged negligence based in part on the railroad employees' failure to blow the whistle and to check and keep checking the train's speed from the blow-post 400 yards from the crossing until reaching the crossing, as required by Georgia law. The railway company answered that its train was operating in interstate commerce and alleged specific facts showing that, over a 123-mile stretch between Atlanta and the Savannah River, the line crossed 124 public roads at grade, so compliance with the statute would add more than six hours to the trip of the train in question and make the total running time more than ten and one-half hours. On demurrer, the trial court struck those constitutional averments from the answer.

Issue

Whether Georgia's statute requiring an engineer approaching each public crossing to blow the whistle and simultaneously check and keep checking speed so as to stop in time is unconstitutional as applied to this interstate train, where the railroad alleged detailed facts showing that compliance at numerous crossings would seriously impede operation of interstate service. Also presented was whether the trial court erred in sustaining a demurrer to those factual allegations.

Rule

A state may regulate railroad crossings under its police power, but it may not do so in a way that directly burdens interstate commerce. When specific alleged facts show that requiring interstate trains to check speed at all crossings on a route because of their number and proximity would be practically destructive of successful interstate train operation, the statute is unconstitutional as applied.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

North Valley Rail runs an interstate passenger train from Birmingham, Alabama, to Charlotte, North Carolina. South Carolina applies a statute requiring engineers to begin checking speed 500 yards before every public grade crossing and keep speed checked until the train reaches the crossing; on a 110-mile segment near Greenville there are 118 public crossings, and the railroad specifically alleges compliance would add at least five and a half hours to a scheduled four-hour run.

If these allegations are accepted as true on demurrer, which is the strongest argument for the railroad?

Explanation. The majority held that a state may regulate crossings under its police power, but not in a way that directly burdens interstate commerce. Where specific facts show crossings are so numerous and so near together that required speed checking at all of them would be practically destructive of successful interstate train operation, the statute is unconstitutional as applied. The decision was not facial, and it did not depend on conflicting federal legislation. (Derived from Seaboard Air Line Railway v. Blackwell (n.d.).)