1898 United States Supreme Court case
Smyth v. Ames Submitted May 9, 1898 Full case name Smyth, Attorney General, et al. v. Ames, et al.; Smyth, Attorney General, et al. v. Smith, et al.; Smyth, Attorney General, et al. v. Higginson, et al. Citations 171U.S. 361 (more Holding VoidedNebraska railroad tariffs and defined the constitutional limits of governmental power to set railroad and utility rates. Court membership Chief Justice Melville Fuller Associate Justices John M. Harlan · Horace Gray David J. Brewer · Henry B. Brown George Shiras Jr. · Edward D. White Rufus W. Peckham · Joseph McKenna Case opinion Majority Harlan, joined byunanimous Laws applied Fourteenth Amendment to the United States Constitution ,Contract Clause Overruled by
Federal Power Commission v. Hope Natural Gas Co. , 320 U.S. 591 (1944)
Smyth v. Ames The Maximum Freight Case Supreme Court case .[ 1] Nebraska railroad tariff law, declaring that it violated theFourteenth Amendment to the United States Constitution in that it takes property without the due process of law.[ 2] Federal Power Commission v. Hope Natural Gas Company [ 3] [ 4]
The decision inSmyth v. Ames was unanimous and JusticeJohn M. Harlan delivered the opinion of the Court in writing.[ 5]
On April 12, 1893,[ 6] [ 2] Railroad Commissioners of Nebraska were empowered to reduce any freight rate.[ 6]
Several precedents had been set by the Supreme Court regarding state control over railways. UntilMunn v. Illinois Granger Laws were declared constitutional, it had been held that railway property was protected from state authority by theContract Clause of the Constitution, which states that no state shall pass any "Law impairing the Obligation of Contracts". However, in the Munn case, the Court ruled that all property was held subject to legislative regulation if it was "affected with a public interest". Further decisions built off the Munn decision, specifying that while the legislature may regulate property "affected by the public interest", they must exercise it reasonably by applying theused and useful principle , so as to not deprive citizens of their property withoutdue process of law.[ 7]
The maximum rate law was contested by theUnion Pacific ,St. Joseph and Grand Island Railway ,Omaha and Republican Valley Railway , and theKansas City and Omaha Railway . They claimed the law was confiscation, and therefore unconstitutional.[ 6] $ 2,250,00 annually.[ 8]
The Supreme Court unanimously found the law unconstitutional. The court found that it is not enough to show a tariff – even if the tax is in the public interest – still leaves a company enough money to pay operating expenses and stock dividends.[ 9]
Effects of the decision [ edit ] Businessmen were pleased by the decision, and believed it would give stability to railroad investments.[ 10] [ 11]
TheInterstate Commerce Commission was weakened by the Court's decision.[ 12]
The ruling was overturned in the 1944 case ofFederal Power Commission v. Hope Natural Gas Co. [ 3] [ 4] Constantine Joseph Smyth , later served as Chief Justice of theCourt of Appeals of the District of Columbia .
^ Smyth v. Ames , 171 U.S. 361 (1898).^a b Public Opinion: A Comprehensive Summary of the Press Throughout the World on All Important Current Topics ^a b Federal Power Commission v. Hope Natural Gas Co. , 320 U.S. 591 (1944).^a b Siegel, Stephen A.Smyth v. Ames .Answers.com . Accessed 18 February 2009 ^ "Smyth v. Ames, 169 U.S. 466 (1898)" .Justia Law . RetrievedAugust 20, 2024 .^a b c "Nebraska Law Invalid" (PDF) .NYT . March 8, 1898. RetrievedFebruary 18, 2009 .^ "The central law journal" .The Central Law Journal .46 (24). St. Louis, MO: Soule, Thomas & Wentworth: 489. June 10, 1898. RetrievedFebruary 18, 2009 .^ Colby, Frank Moore (1899).The International Year Book ^ The Nation ^ "Maximum Rate Decision" (PDF) .NYT . March 9, 1898. RetrievedFebruary 18, 2009 .^ Shaw, Albert (1898).Review of Reviews and World's Work: An International Magazine ^ Myers, Gustavus (1912).History of the Supreme Court of the United States
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