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Law School Case Brief

S. Pac. Co. v. Arizona - 325 U.S. 761, 65 S. Ct. 1515 (1945)


Although the Commerce Clause conferred on the national government power to regulate commerce, its possession of the power does not exclude all state power of regulation. It has been recognized that, in the absence of conflicting legislation by Congress, there is a residuum of power in the state to make laws governing matters of local concern which nevertheless in some measure affect interstate commerce or even, to some extent, regulate it. Thus the states may regulate matters which, because of their number and diversity, may never be adequately dealt with by Congress. When the regulation of matters of local concern is local in character and effect, and its impact on the national commerce does not seriously interfere with its operation, and the consequent incentive to deal with them nationally is slight, such regulation has been generally held to be within state authority. 


The Arizona Train Limit Law of 1912 made it unlawful for any person or corporation to operate within the state a railroad train of more than 14 passenger or 70 freight cars, and authorized the state to recover a money penalty for each violation of the Act. In 1940, the State of Arizona brought suit against the Southern Pacific Company to recover the statutory penalties for operating within the state two interstate trains, one a passenger train of more than fourteen cars, and one a freight train of more than seventy cars. The company answered, admitting the train operations, but defended on the ground that the statute offends against the commerce clause and the due process clause of the Fourteenth Amendment and conflicts with federal legislation. The trial court found that the Arizona law had no reasonable relation to safety, and made train operation more dangerous. The Supreme Court of Arizona upheld the constitutionality of the Arizona Train Limit Law. The case was appealed.


Did the Arizona Train Limit Law contravene the Commerce Clause of the Federal Constitution in that it regulated the length of interstate trains as a purported safety measure?




The Supreme Court of the United States held that although the Commerce Clause conferred on the national government power to regulate commerce, its possession of the power did not exclude all state power of regulation. However, the Court found that the states were not deemed to have authority to impede substantially the free flow of commerce from state to state, or to regulate those phases of the national commerce which, because of the need of national uniformity, demanded that their regulation be prescribed by a single authority. The Court concluded that § 69-119 of the Arizona Train Limit Law went too far, having a seriously adverse effect on transportation efficiency and economy, and passed beyond what was plainly essential for safety. The Law's undoubted effect on the commerce was the regulation, without securing uniformity, of the length of trains operated in interstate commerce, which lack is itself a primary cause of preventing the free flow of commerce by delaying it and by substantially increasing its cost and impairing its efficiency. Examination of all the relevant factors made it plain that the state interest was outweighed by the interest of the nation in an adequate, economical, and efficient railway transportation service, which must prevail. Accordingly, the Court reversed the judgment.

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