Rahul Sharma (Editor)

Wabash, St. Louis and Pacific Railway Co. v. Illinois

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Date decided
  
1886

Citations
  
118 U.S. 557 ()

Wabash, St. Louis & Pacific Railway Co. v. Illinois httpsmstartzmanpbworkscomf1263250241wabashjpg

Full case name
  
Wabash, St. L. & P. Ry. Co. v. People of State of Illinois

Majority
  
Miller, joined by Field, Harlan, Woods, Matthews, Blatchford

Dissent
  
Waite, joined by Bradley, Gray

Ruling court
  
Supreme Court of the United States

Similar
  
Munn v Illinois, United States v E C Knight, Muller v Oregon, Fletcher v Peck, ALA Schechter Poultry C

Wabash, St. Louis & Pacific Railway Company v. Illinois, 118 U.S. 557 (1886)[1], also known as the Wabash Case, was a Supreme Court decision that severely limited the rights of states to control interstate commerce. It led to the creation of the Interstate Commerce Commission.

Contents

The court

The majority's opinion was written by Justice Samuel Miller; joining him were Justices Stephen Field, John Harlan, William Woods, Thomas Matthews, and Samuel Blatchford. Dissenting were Chief Justice Morrison Waite and Justices Joseph Bradley and Horace Gray.

The case

The case was argued on April 14, 1886 - April 15, 1886 and was decided on October 25, 1886 by vote of 6 to 3. Associate Justice Miller wrote for the Court with Associate Justices Field, Harlan, Woods, Matthews, and Blatchford concurring; Associate Justices Bradley and Gray, along with Chief Justice Waite, dissented.

In Wabash, "direct" burdens on interstate commerce were not permitted by the Export Tax Clause of the Constitution (Article I, Section 9); however, those "indirect" burdens were permitted under the Commerce Clause. This was a standard enacted in Cooley v. Board of Wardens (1852).

Effects of decision

  • The Wabash decision led to the creation in 1887 of the first modern regulatory agency, the Interstate Commerce Commission.
  • It clarified the "direct" v. "indirect" test (though this doctrine was abandoned in the 1930s).
  • It was one of the first instances in government assuming responsibility for economic affairs that had previously been delegated to the states.
  • References

    Wabash, St. Louis & Pacific Railway Co. v. Illinois Wikipedia