HOUSTON, EAST &WEST TEXAS RAILWAY V. UNITED STATES (THE SHREVEPORT CASE) 234 U.S. 342 (1914) CASE BRIEF

HOUSTON, EAST &WEST TEXAS RAILWAY V. UNITED STATES (THE SHREVEPORT CASE)

234 U.S. 342 (1914)

NATURE OF THE CASE: This was a dispute over an Interstate Commerce Commission Order.

FACTS: The Interstate Commerce Commission alleged that discrimination was being laid against Shreveport. It ordered the carriers who served that city to desist from charging higher rates for the transportation of any commodity from Shreveport to Dallas and Houston, respectively and intermediate points, than were contemporaneously charged for the carriage of such commodity from Dallas and Houston toward Shreveport for equal distances, as the Commission found that relations of rates to be reasonable. Ds opposed this rate setting provision as they wanted a ruling that the Commission was without authority to compel their reduction in order to equalize them with the lower intrastate rates. The Commerce Court held that Ds were relieved of the obligation to lower rates but that they were at liberty to comply with the Commission's requirements by increasing rates sufficiently on the intrastate routes to remove the forbidden discrimination. Ds appealed. The invalidity of the order in this aspect is challenged upon two grounds: (1) That Congress is impotent to control the intrastate charges of an interstate carrier even to the extent necessary to prevent injurious discrimination against interstate traffic; and (2) That, if it be assumed that Congress has this power, still it has not been exercised, and hence the action of the Commission exceeded the limits of the authority which has been conferred upon it under the Commerce Clause.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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