Chicago, Minn. & St. Paul Ry. Co. v. Minnesota

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Case Basics
Docket No.: 
762
Petitioner: 
Chicago, Minn. & St. Paul Ry. Co.
Respondent: 
Minnesota
Decided By: 
Fuller Court (1890)
Opinion: 
134 U.S. 418 (1890)

Cite this page
The Oyez Project, Chicago, Minn. & St. Paul Ry. Co. v. Minnesota , 134 U.S. 418 (1890)
available at: (http://oyez.org/cases/1851-1900/1889/1889_762)
Facts of the Case: 

A Minnesota law made its railroad commission the final judge of the reasonableness of railroad rates. The railroad maintained that "it is always a judicial question as to whether a statute is repugnant to provisions of the constitution."

Question: 

Does the Minnesota law violate the due process clause of the 14th Amendment?

Conclusion: 

Yes. The statute did not provide procedural due process: railroads received no hearing or other chance to defend their rates before the commission. Moreover, a rate's reasonableness "is eminently a question for judicial investigation, requiring due process of law for its determination." A company denied the authority to charge a reasonable rate and unable to turn to a judicial mechanism for review would be deprived of the "lawful use of its property, and, thus, in substance, and effect, of the property without due process of law."