Southern Pacific Co. v. Arizona

Brief Fact Summary.

The appellant challenged the Arizona state act that prohibits anyone from operating within the state a railroad train of more than fourteen passenger or seventy freight cars and authorizes the state to recover a money penalty for each violation of the Act.

Synopsis of Rule of Law.

Without controlling congressional action, a state may not regulate interstate commerce so as substantially to affect its flow or deprive it of needed uniformity in its regulation.

Facts.

The Arizona Train Limit Law of 1912 makes it unlawful for anyone or corporation to operate within the state a railroad train of more than fourteen passenger or seventy freight cars and authorizes the state to recover a money penalty for each violation of the Act.

Issue.

Has Congress, by legislative enactment, restricted the power of the states to regulate the length of interstate trains as a safety measure?

Held.

No, the Arizona state statute contravenes the commerce clause of the federal Constitution. The statute went too far because its regulation of train lengths, admittedly obstructive to interstate train operation, and having a seriously adverse effect on transportation efficiency and economy, passes beyond what is plainly essential for safety since it does not appear that it will reduce rather than increase the danger of accident.

Discussion.

The Arizona Train Limit Law, viewed as a safety measure, affords at most slight and dubious advantage, if any, over unregulated train lengths, because it results in an increase in the number of trains and train operations and the subsequent increase in train accidents of a character generally more severe than those due to slack action. Appellees referred to the train laws in South Carolina Highway Dept. as their supporting authority. However, the train laws in that case placed an additional financial burden on the railroads to serve a local interest, but they did not obstruct interstate transportation or seriously impede it. They had no effects outside the state. In the current case, the relevant facts show that the state interest is outweighed by the nation’s interest in an adequate, economical and efficient railway transportation services which must prevail.