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Wabash, St. Louis & Pacific Railway Company v. Illinois, 118 U.S. 557 (1886) resulted from a dispute between the railway company and the state of Illinois arising from shipping charges for hauling cargo from various cities in Illinois to cities in other states.

Illinois law prohibited charging higher freight for moving goods shorter distances than for longer distances. Specifically at issue was the fact Wabash charged more to transport goods from Gilman, Illinois to New York than from Peoria, Illinois, to New York, even though the distance from Gilman to New York was 86 miles shorter.

The ruling overturned Munn v. Illinios (1877) which rejected the railroads declaration of the Granger Laws unconstitutional. Wabash vs. Illinios (1886) modified this position by prohibiting states from regulating railroad rates.

Congress passed the Interstate Commerce Act (1887), reaffirming the federal government's power to investigate and oversee railroad activities, and then established a new agency (The interstate Commerce Commission - ICC) to do just that.

Case Citation:

Wabash, St. Louis & Pacific Railway Company v. Illinois, 118 U.S. 557 (1886)

While the Interstate Commerce Act and the ruling in Wabash failed to curb railroads' monopolistic practices, it did establish the right of federal regulation over interstate transportation.

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13y ago

Wabash, St. Louis & Pacific Railway Company v. Illinois, (1886) resulted from a dispute between the railway company and the state of Illinois over shipping charges for transporting cargo from various cities in Illinois to cities in other states.

Illinois law prohibited charging higher freight for moving goods shorter distances than for moving them longer distances, and imposed fines on railroad companies that failed to comply with their regulations. Specifically at issue was the fact Wabash charged more to transport goods from Gilman, Illinois, to New York than from Peoria, Illinois, to New York, even though the distance from Gilman to New York was 86 miles shorter.

The US Supreme Court held that the Illinois statute prevented the state from regulating freight charges based on the specific point of departure, concluding that a voyage consisted of departure from anywhere in the interior of Illinois to New York (the ruling could be generalized to other states and destinations).

The Court further held that the case involved a matter of "commerce among the states," which was properly regulated by Congress, not the States, per the US Constitution's Commerce Clause (Article I, Section 8, Clause 3) and its Necessary and Proper Clause* (Article I, Section 8, Clause 18).

The Court declared that the decision in Wabash did not establish a contrary doctrine to rulings in earlier cases, such as Munn v. Illinois, 94 U. S. 113 (1877); Chicago, Burlington & Quincy Railroad Co. v. Iowa, 94 U. S. 155, (1876) and Peik v. Chicago & Northwestern Railway, 94 U. S. 164 (1876).

The decision of the Illinois court was reversed, and the State's transportation statute struck down as unconstitutional.

Case Citation:

Wabash, St. Louis & Pacific Railway Company v. Illinois, 118 U.S. 557 (1886)

* The Necessary and Proper Clause is variously known as the Elastic Clause, the Basket Clause, the Coefficient Clause, and the Sweeping Clause, all of which refer specifically to the US Constitution Article I, Section 8, Clause 18.

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11y ago

Only states can regulate the rates railroads the rates railroads charge for transporting freight

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Q: What was the US Supreme Court decision in Wabash v Illinois?
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