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Southern Railway Co. v. United States

Supreme Court of the United States · 1911 · Constitutional Law

Constitutional LawCommerce ClauseSafety Appliance ActsCommerce Clauseinterstate commerceintrastate commercerailroad safetySafety Appliance Act

Facts

Southern Railway operated a railroad that was part of a through highway over which traffic was continually moved from one state to another. In February 1907, it hauled five cars with defective and inoperative couplers over part of its railroad. Two cars were being used in moving interstate traffic, while three were being used in moving intrastate traffic, and it did not appear that the three intrastate cars were used in connection with cars moving interstate traffic. The railroad objected to penalties for the three intrastate cars, arguing that the Acts did not cover them and, if they did, the Acts exceeded Congress's commerce power.

Issue

Do the Safety Appliance Acts, as enlarged by the 1903 amendment, apply to cars used only in intrastate traffic when those cars are used on a railroad that is a highway of interstate commerce? If so, is that application a valid exercise of Congress's power under the Commerce Clause?

Rule

The Safety Appliance Acts, as amended in 1903, apply to all locomotives, cars, and similar vehicles used on any railroad engaged in interstate commerce, regardless of whether a particular vehicle is at the time moving interstate or intrastate traffic. Congress may impose such requirements on vehicles used in intrastate traffic when there is a real or substantial relation between the regulation and the safety of interstate commerce and those employed in it.

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

Redstone Rail Lines operates track running from Tennessee into Kentucky and also handles local freight entirely within Tennessee. In Nashville, it hauls a boxcar loaded only with intrastate lumber, and the car's automatic coupler is defective. The car is not attached to any interstate shipment at that moment.

Is a federal safety-appliance penalty most likely valid as applied to the defective boxcar?

Explanation. The majority read the statute to cover all cars used on any railroad engaged in interstate commerce, not merely cars then moving interstate traffic. It also held that Congress may reach intrastate-use cars on such a railroad because applying safety requirements to them bears a real or substantial relation to the safety of interstate commerce and the employees engaged in it.