Law School Case Brief
S. R. Co. v. United States - 222 U.S. 20, 32 S. Ct. 2 (1911)
The question is whether the Safety Appliance Acts of Congress of March 2, 1893, ch. 196, 27 Stat. 531, as enlarged by the amendatory Act of March 2, 1903, ch. 976, 32 Stat. 943, are within the power of Congress under the Commerce Clause of the United States Constitution, considering that they are not confined to vehicles used in moving interstate traffic, but embrace vehicles used in moving intrastate traffic. The answer to this question depends upon another, which is, Is there a real or substantial relation or connection between what is required by these acts in respect of vehicles used in moving intrastate traffic and the object which the acts obviously are designed to attain, namely, the safety of interstate commerce and of those who are employed in its movement? If the answer to this question be in the affirmative, then the principal question must be answered in the same way. And this is so, not because Congress possesses any power to regulate intrastate commerce as such, but because its power to regulate interstate commerce is plenary and competently may be exerted to secure the safety of the persons and property transported therein and of those who are employed in such transportation, no matter what may be the source of the dangers which threaten it.
The railway, while operating a railroad which was "a part of a through highway" over which traffic was continually being moved from one state to another, hauled over a part of its railroad three cars with defective couplers in moving intrastate traffic. The railway particularly objected to the assessment of any penalty for the hauling of the three cars, insisting that such a hauling in intrastate traffic was not within the prohibition of the Safety Appliance Act and that even if it was, the Act should be pronounced invalid as being in excess of the power of Congress under the Commerce Clause of the Constitution. The district court overruled the railway's objections.
Was the Safety Appliance Act invalid as being in excess of the power of Congress under the Commerce Clause of the Constitution as applied to hauling defective couplers in intrastate railways?
The Court found that the words "on any railroad engaged" in the first clause of the Act mean "the use of the vehicle on a railroad that is a highway of interstate commerce," and not its use in moving interstate traffic. The Court also held that the Act was within the power of Congress under the Commerce Clause of the Constitution because cars were seldom set apart for exclusive use in moving either class of traffic, but generally were used interchangeably in moving both interstate and intrastate. The absence of appropriate safety appliances from any part of any train was a menace not only to that train but to others.
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