Charles River Bridge v. Warren Bridge

Brief Fact Summary.

Plaintiff sought an injunction to prevent the defendants’ bridge’s construction that was also approved by Congress.

Synopsis of Rule of Law.

A court may not infer an existence of a prohibition, if legislation authorizes a corporation to make public improvements, without any prohibitions.

Facts.

Congress passed and act that allowed Plaintiff Proprietors of the Charles River Bridge to replace a ferry with a bridge over the Charles River. Congress then allowed Defendants the Proprietors of the Warren Bridge to build another bridge over the Charles River. Plaintiff sought an injunction to prevent the defendants’ bridge’s construction. The United States Supreme Court heard the case.

Issue.

Whether a court may not infer an existence of a prohibition, if legislation authorizes a corporation to make public improvements, without any prohibitions.

Held.

No. The Supreme Judicial Court’s judgment is affirmed.

Dissent.

The plaintiff would likely have not constructed the bridge had it known that Congress intended to reserve the right to build a competing free bridge. Defendants’ bridge should be located a sufficient distance from the plaintiff’s bridge to prevent competition. The Supreme Judicial Court’s dismissal of the bill should be reversed.

Discussion.

In this case, the plaintiff must show that the state entered a contract not to establish a free bridge. The state’s power to promote community happiness must not be abandoned by implication or presumption for the benefit of privileged corporations.