Ann Arbor Railroad v. Railroad Commission

8 Ohio N.P. (n.s.) 233

This text of 8 Ohio N.P. (n.s.) 233 (Ann Arbor Railroad v. Railroad Commission) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ann Arbor Railroad v. Railroad Commission, 8 Ohio N.P. (n.s.) 233 (Ohio Super. Ct. 1909).

Opinion

Kineead, J.

The questions arise upon demurrer to the second cause of action.

Plaintiffs (thirty-five railroads), for their second'cause of action, aver that the defendant commission on March 20, 1908, made an order determining and fixing certain car service charges, regulations and practices, to be imposed, observed and followed in the future by all the plaintiff railroad companies.

The petition thereupon sets forth each and all of the rules so made and now complained of.

Without enumeration or going into details, it may be stated that the only question urged in argument relates to car service regulations, objection being made by plaintiffs to rules allowing [234]*234forty-eight hours free time for cars containing 66,000 pounds, and seventy-two hours for ears containing more than 66,000. Objection is made also to other allowances and increases of free time for car service.

It is claimed that rules 1, 2, 6, 12 ,and 14 are applicable to ears in transit; that the remainder of the rules relate to the receipt and delivery of property at the commencement and end of the carriage; that is, they regulate the free time which shall be allowed for the loading and unloading of cars, the charges which may be made for over-detention for such purposes, and the method of calculating such charges.

It is claimed that the receipt and delivery of property for interstate transportation, and the detention of cars for that purpose, is a part of the interstate commerce therein.

It is claimed that the delivery of cars to a shipper for loading of freight which is to be transported by the carrier from the place where the same is loaded to another state, is as much a part of Interstate carriage as when the car and its contents are in transit. ' '

The same claim is made in respect to freight delivered in cars in public or private loading places to be unloaded by the consignee ; that interstate commerce does not end until the consignee has unloaded and relinquished the car.

It is conceded that the railroad commission’ has power simply to regulate intrastate commerce, but it is contended that it has, by the rules complained of, directly and immediately regulated interstate commerce.

It will readily be conceded that the cars of the plaintiff; carriers are used indiscriminately in state and interstate transportation.

This being true, it is plain that if the rules apply and govern the use of all ears whether in state or interstate commerce, their detention indiscriminately according to the provisions of these rules, will constitute a restriction upon interstate commerce.

The -rules in question which authorize the detention by consignees and consignors for the periods prescribed for -interstate shipments, constitute a direct infringement of the constitutional [235]*235right of Congress to regulate commerce, as well as a violation of the interstate commerce act, provided such interstate commerce begins when the ear is delivered to the consignor for loading, and ends only when the same is unloaded by the consignee.

But the claim of the railroad companies is carried farther than this, however. It is .argued that the detention of cars for purposes of state commerce, has an indirect effect upon interstate commerce, because the total volume of available equipment is diminished by such detention, and the railroad..affected, therefore, has fewer available ears for both state and interstate business than it would have if such detention were not permitted or were permitted for only a shorter time.

It is apparent, therefore, that if .the contention of the railroad company be the correct and sound position, and interstate commerce does begin when the cars ¡are placed at the disposal of the shipper by the company for loading, then the prevailing rule which has existed for so long, which does not impose the responsibility of the carrier, as such, until the car is loaded and the bill of lading is delivered to the shipper, will necessarily be ignored.

To reach the conclusion that interstate commerce begins when the car is delivered to the shipper, there must be some very potent and sound reasons for creating an exception to the familiar and long prevailing rule referred to.

If it is to be decided that interstate commerce does not end until the • consignee has entirely unloaded the car, and thus relinquished it, in reliance upon the ordinary rule fixing the responsibility of the carrier, it might be urged that the same theory or principle should control in determining when interstate commerce begins.

The application of such a doctrine would result in one rule regulating the commencement of interstate commerce, and another the time of its eompletbion.

The conditions and equitable adjustment of the rights of shipper, consignee and carrier in matters of liability for loss and responsibility therefor, have no relation or bearing upon the broad and comprehensive question of interstate commerce involved in determining the most advantageous methods of use and manipula[236]*236tions of the immense equipment of the railroad systems, and consequent rules of law which shall be formulated to produce the best results, and to promote and foster interstate commerce between the states.

It is a well known fact that, in this modern age, the greatest percent of supplies for nearly every want are chiefly carried by means of interstate commerce shipments, either by way of importation or exportation. Almost everything we eat, for example, come from other states by means of interstate railroads. And many other things might be enumerated to show the magnitude and importance of the function of the great .arteries of interstate commerce in the service of the people of the states. We must have in mind the convenience not only of the citizenship of one state, but of all.

The railroad in the state which does not engage in interstate commerce to some extent would be difficult to find.

A striking example of the abuses that may result from the enforcement of such rules as the railroad commission has enacted is well illustrated in the Pittsburg ease, hereinafter cited, where the consignees of car load shipments of southern products used the cars from which to display their goods and sell them, converting the instruments of interstate commerce into local warehouses, to the disadvantage of shippers. The rules complained of extending the free time would tend to foster such abuses.

Those who have been giving special attention to freight car manipulation are alive to the situation. It is conceded on all hands that there ought to be proper regulation by competent authority to correct abuses on the part of railroad or shipper. The criticism of the association of railroad commissioners is of interest. Their report reads:

“It is to the interest of shippers that many concessions made by the railroads in the way of free time for cars should be withdrawn. The individual shipper who succeeds in using a coal ear as a warehouse for ten or fifteen days free of charge may profit thereby, but he does so at the expense of other shippers who are entitled to have the use of the car for transportation of their coal. The pressure of the individual shippers to secure additional free time is really directed against the proper use of [237]*237cars ¿nd against the best interests of the shipping public .as a whole.

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Bluebook (online)
8 Ohio N.P. (n.s.) 233, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ann-arbor-railroad-v-railroad-commission-ohctcomplfrankl-1909.