SOUTHERN PACIFIC CO. V. ARIZONA 325 U.S. 761 (1945) CASE BRIEF

SOUTHERN PACIFIC CO. V. ARIZONA

325 U.S. 761 (1945)

NATURE OF THE CASE: This is an appeal of a state supreme court decision that the state's suit to recover statutory penalties was valid despite a commerce clause challenge.

FACTS: The Arizona Train Limit Law of 1912 prohibited operating railroad trains of more than 14 passenger or 70 freight cars. In 1940 the State sued the Company to recover statutory penalties for violating the law. The operation of long trains is standard practice over the main lines of the railroads of the United States. Compliance with a state statute limiting train lengths requires, in practical effect, that interstate trains of a length lawful in other states be broken up and reconstituted as they enter each state, or that interstate trains conform to the lowest train limit restriction of any state through which such trains pass. The trial court found that the Arizona law had no reasonable relation to safety; this finding was based on the fact that such increased danger of accident and personal injury as may result from the greater length of trains is more than offset by the increase in the number of accidents resulting from the larger number of trains when train lengths are reduced. The trial court found the law to be an unconstitutional burden on commerce. The Arizona Supreme Court reversed, concluding that a state law enacted in the exercise of the police power, with some reasonable relation to health and safety, could not be overturned despite its adverse effect on interstate commerce.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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