Chicago, Milwaukee & St. Paul Railway Company v. Minnesota

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Chicago, Milwaukee & St. Paul Railway Company v. Minnesota

Decided March 24, 1890

Full case name:	Chicago, Milwaukee, St. Paul and Pacific Railroad Company v. State of Minnesota ex rel. Railroad and Warehouse Commission

Citations:	134 U.S. 418

Holding

Substantive due process applies to state regulatory action.

Court membership

Chief Justice: Melville Fuller
Associate Justices: Stephen Johnson Field, Joseph Philo Bradley, John Marshall Harlan, Horace Gray, Samuel Blatchford, Lucius Quintus Cincinnatus Lamar II, David Josiah Brewer

Case opinions

Majority by: Blatchford
Concurrence by: Miller
Dissent by: Bradley
Joined by: Gray, Lamar

Chicago, Milwaukee & St. Paul Railway Company v. Minnesota, 134 U.S. 418 (1890),^[1] was a case in which the Supreme Court of the United States held that substantive due process limits state regulatory power over railroad rates. A regulatory agency in Minnesota had set railroad rates that the Minnesota Supreme Court had refused to overturn. The U.S. Supreme Court found that the rates were set without due process of law, specifically without an opportunity to challenge the equality and reasonableness of the charges. The Minnesota court had sanctioned rate-setting without any judicial hearing, requirement of notice or witnesses, "-in fact, nothing which has the semblance of due process of law"^[2].

The court rejected the railroad's argument that the state's contract with the Minnesota railroad line, as it existed in prior state-chartered companies that the railroad later bought, remained in force against state law. Instead, they found that the state's right to regulate industry could not be forfeited except by an explicit declaration in law. However, this issue was subsumed by the court's broader decision regarding due process.

Justice Bradley strongly dissented from the decision, indicating that it practically overturned Munn v. Illinois and other railroad cases that left states to decide toll rates. He indicated that it was the provence of the states to decide the policy question of railroad rates, and not that of the judiciary.