HOUSTON, EAST AND WEST TEXAS RAILWAY CO. v. UNITED STATES
The Houston, East and West Texas Railroad and the Texas and Pacific Railway were railroad companies operating rail lines between Shreveport, Louisiana and points in Texas. The Texas Railroad Commission mandated that they charge higher rates on freight travelling between Louisiana and Texas than on freight travelling solely within Texas. The Interstate Commerce Commission (ICC) found that the interstate rates were unreasonable and illegally discriminated against freight traffic originating in Shreveport. The ICC established maximum rates and ordered the railroads to fix their intrastate rate schedules. The railroads challenged the order in United States Commerce Court, alleging that the ICC did not have the power to regulate intrastate commerce. The Commerce Court upheld the ICC order. The railroads then appealed to the Supreme Court.
Did the ICC have the power to regulate the railroads' intrastate rates?
Yes. In a 7-2 decision, the Court affirmed the Commerce Court and upheld the ICC order. Congress was granted the power to regulate interstate commerce, which it chose to do through the ICC. This power extended to "matters having such a close and substantial relation to interstate traffic," Justice Charles Evans Hughes wrote for the majority. Since the price discrimination adversely affected interstate commerce, "it is immaterial…that the discrimination arises from intrastate rates as compared with interstate rates." Therefore, the railroads' intrastate rates were subject to regulation and the ICC order was valid.