Houston, East & West Texas Ry. v. United States

Brief Fact Summary.

The government brought suit against railway companies in Texas who were charging lower rates for intrastate shipments and higher rates for out-of-state shipments.

Synopsis of Rule of Law.

Congress may control intrastate commerce in order to protect interstate commerce.

Facts.

Railway companies in Texas were charging more for shipments from Shreveport, Louisiana to be shipped into Texas than for similar shipments that were made within the state of Texas. The government brought suit against these railway companies, arguing that the rate discrepancy negatively impacted interstate commerce.

Issue.

May Congress regulate carriers engaged in intrastate commerce if those carriers are also engaged in interstate commerce?

Held.

Yes.

Discussion.

Congress’ authority extends to interstate carriers, as instruments of interstate commerce. Congress possesses the power to foster and protect interstate commerce, and to take all measures necessary or appropriate to that end. Within that power is the authority to regulate intrastate transactions of interstate carriers. Otherwise, interstate commerce would otherwise be impeded by the rivalries of local government.