Wabash, St. Louis & Pacific Railroad Company v. Illinois

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Wabash, St. Louis & Pacific Railroad Company vs. Illinois, 118 U.S. 557 (1886)^[1], also known as the Wabash Case or 'Adam', was a United States Supreme Court case that severely limited the rights of states to control interstate commerce. It led to the creation of the Interstate Commerce Commission.

1 The court
2 The case
3 Effects of decision
4 See also
5 External links
6 References

[edit] 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.

[edit] 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, the Court had to decide whether states have the power to regulate railroad rates for interstate shipments. It ruled that the Commerce Clause does not permit states to enact "direct" burdens on interstate commerce (noting, however, that "indirect" burdens were permitted under the Commerce Clause). This was a significant departure from the accepted standard enacted in Cooley v. Board of Wardens (1852).

It should be noted, however, that Wabash did not strip states of all power to regulate interstate railroads. For example, the state safety regulations remained as allowed "indirect" burdens. However, prior to Wabash, the federal government yielded the subject of railroad regulation to the states; Wabash made rate regulation of shipments between states a protected federal power.

Spurred by this decision, Congress established the Interstate Commerce Commission in 1887, the first regulatory agency. Wabash can thus be said to have led to the creation of the modern regulatory agency and signaled the movement of the national government to assume responsibility for economic affairs which was previously delegated to the states.

[edit] Effects of decision

The Wabash decision led to the creation 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.