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."