In re Motions to Quash in the Atlantic Coast Line

4 Balt. C. Rep. 315
CourtBaltimore City Court
DecidedSeptember 18, 1924
StatusPublished

This text of 4 Balt. C. Rep. 315 (In re Motions to Quash in the Atlantic Coast Line) is published on Counsel Stack Legal Research, covering Baltimore City Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Motions to Quash in the Atlantic Coast Line, 4 Balt. C. Rep. 315 (Md. Super. Ct. 1924).

Opinion

STEIN, J.

There are eleven of these suits; each brought under the "Carmack Amendment,” to recover damages for “failure to keep a contract for the safe delivery of freight.” In ten, the Atlantic Coast Line, the “initial carrier,” is sued jointly, with the connecting and terminal carrier; in the other, the “Southern Railway” the “initial carrier” is the sole defendant.

Each is a foreign corporation, incorporated under the laws of the State of Virginia, as a common carrier, to engage in intra and interstate freight and passenger traffic. Neither has any line or railroad tracks in Maryland.

The cause of action in each suit, is based on a “contract of freight” for an interstate commerce shipment; tlie contract was not entered into in tlic State of Maryland; but was entered into in another Slate, in the course of the carrier’s “interstate commerce” business.

Each, above named defendant, specially appeared in each case by counsel, and filed a motion to quash the writ of summons because:

A. Each is a foreign corporation, whose sole business in Maryland, is the solicitation of freight and passenger traffic in interstate commerce business ; which ’business the Supreme Court of the United States under the “due process” clause of the Federal Constitution, holds does not make the carrier “so present” in Maryland, as to give the Courts of that State jurisdiction over it. in a suit to enforce personal liability.

B. That, if under the Maryland statutes authorizing suits against foreign corporations, doing business therein, each carrier is “so present” as to subject it to these suits; yet they cannot be maintained, because the bringing of each in Maryland is an “undue burden” on Interstate commerce under the Davis case, 202 U. S. 312, &c. And, if they authorize the bringing of these suits (he Maryland statutes conflict with the “Commerce Clause of the Federal Constitution” and to that extent are invalid.

These are Federal questions. Rerhaps the Supreme Court of the United States could be called upon to review the decisions of the State Courts therein : which review, if made, would extend to “findings of facts as well as to conclusions of law;” McKibbins’ Case, 243 U. S. 204 at 205.

The motions were heal’d together, upon the following record, viz.: (a) The affidavit of one of the plaintiffs; (b) several agreed statements of facts; (c) the oral testimony of Mr. IVaixliu, the officer of the Atlantic Coast Line, upon whom summons was served in each case against it; and (d) the official timetable each carrier issues and distributes to the public in Maryland and elsewhere.

From that record I find : Each carrier is a foreign corporation, engaged in interstate commerce, without any line or tracks in Maryland; that the ears of each run over other lines in Maryland —either for discharge therein or to pass through; that each carrier maintains an office in the City of Baltimore, in charge of its officers, employed to solicit freight and passenger traffic [316]*316over its lines in other States; each carrier, in some way, is subject to taxation in Maryland. While from the above ancl the other facts in this record, the inference could be drawn that each corporation was and is engaged in the doing of other kinds of business in Maryland, yet this opinion will accept counsels’ contention, that each carrier's business in Maryland was and is the solicitation therein of “interstate commerce” freight and passenger traffic in other States.

The question under the due process clause is a difficult one — due to two (at times conflicting) views, upon which State jurisdiction over foreign corporations is based. Starting from the common principle that a corporation cannot “migrate,” came two modifications :

(1) If a State statute conditions the transaction of business within its borders (e. g., as to amenability to suit) such conditions, so far as reasonable, will be upheld. This, at times, is called the “implied assent” theory; and has been applied to insurance companies (Lafayette Insurance Company vs. French, 18 Howard (U. S.) 404) ; as well as to corporations “exclusively engaged in interstate commerce.” (International Harvester Company vs. Kentucky, 234 U. S. 579).

(2) The other theory, logically unconnected with State statutes, treats a foreign corporation as “actually present” by its representatives, if it habitually carries on .some part of Its business in the State. This theory has been applied by the Supreme Court, which from a series of suits against carriers (mostly for personal injuries) brought in States whore the carrier had no line and usually by non-residents — has evolved a somewhat narrow view of what constitutes doing business; has disposed of plaintiffs with the “due process clause”; has announced always that doing business is a question of degree ; incapable of any “all embracing” rule; that each case must stand on its own facts (St. Louis vs. Alexander, 227 U. S. 218) : and that the mere maintenance within a State, by a foreign carrier, of a traffic solicitation and promotion bureau, is not sufficient to make such a carrier, so personally present, as to be liable to suit to enforce personal liability.

In a recent case (P. & R. R. Co. vs. McKibbin, 243 U. S. 264-268) the Supreme Court (Brandeis J.), adopts both theories (italics supplied) as fol-laws:

“A foreign corporation is amenable to process to enforce a personal liability in tlm absence of consent, only, if it is doing business within the State, in such a manner and to such an extent as to warrant the inference that it is present there. And even if it is doing business within the State, the process will be valid only if served upon some authorized agent. * * * Whether the corporation was doing business within the State and whether the person served was an authorized agent are questions vital to the jurisdiction of this Court. * * * Even hiring an office, the employment by a foreign railroad of a district freight and passenger agent to solicit and procure passengers and freight to be transported over the defendant’s line, and having under his direction several clerks and various traveling passenger and freight agents (in Green vs. Chicago, 205 U. S. 530) was held not to constitute ‘doing business’ within the State. Nor would the fact, if established by competent evidence that subsidiary companies did business within the State, warrant a finding that the defendant did business there” (Peterson vs. Chicago, 205 U. S. 361).

In this case, evidence of doing business was of the slightest, and it made little difference which theory was applied.

The decisions are not easily reconcilable. In the Alexander case (supra) jurisdiction was upheld because the resident traffic agent had authority to settle claims.

In the Davis case (262 U. S. 312), brought to the Supreme Court on a writ of error from a Minnesota State Court, its last expression on that point, the Court refused to decide whether or not the service therein of the State Court violated the “due process” clause.

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Cite This Page — Counsel Stack

Bluebook (online)
4 Balt. C. Rep. 315, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-motions-to-quash-in-the-atlantic-coast-line-mdcityctbalt-1924.