Interstate Commerce Commission v. Cincinnati
Interstate Commerce Commission v. Cincinnati: Background
Interstate Commerce Commission v. Cincinnati was a crucial and early case heard by the United States Supreme Court. The decision of Interstate Commerce Commission v. Cincinnati helped lay the framework for what would become American administrative law.
The case of Interstate Commerce Commission v. Cincinnati was argued on March 22nd and March 23rd of 1897 and not decided until May 24th of 1897. The case of Interstate Commerce Commission v. Cincinnati held that the power of administrative agencies is administrative and executive, but never legislative. In addition to this principle, the case of Interstate Commerce Commission v. Cincinnati stated that the scope of authority held by an agency is wholly determined by the agency’s organic statute.
While an administrative agency wishes to assume a traditionally legislative power to construct policy, the power must be granted by the agency’s organic statute and never implied from other forms of the statute. This principle, therefore, applies where the policy involves issues of great consequence. This principle, which was brought forth by the decision of Interstate Commerce Commission v. Cincinnati, was later qualified by other landmark cases such as NBC v. US which offered more expansive powers for administrative agencies in the United States.
Interstate Commerce Commission v. Cincinnati: Details of the Case
The case of Interstate Commerce Commission v. Cincinnati dealt with the Interstate Commerce Commission and their ability to set rate for transport and require rail companies who charge more than their established rate to crease operations. The Interstate Commerce Commission, in response to the Cincinnati, New Orleans and Texas Pacific Railway failing to comply with this order, filed a suit with the 6th Circuit Court of Appeals. This suit was filed by the ICC to secure a legal injunction to require the aforementioned railroads to adhere to the commission’s powers.
Ultimately, the case of Interstate Commerce Commission v. Cincinnati ruled that the Interstate Commerce Commission did not have the right or power to set rates and issue orders requiring all rail companies who charge more than the set rate to cease operations.
Opinion of the Court: Interstate Commerce Commission v. Cincinnati
The Interstate Commerce Committee’s authority was originally granted from the Interstate Commerce Act—the piece of legislation which gave life to the ICC and determined its powers. The Supreme Court of the United States in Interstate Commerce Commission v. Cincinnati considered two possible ways that Congress might endow the power to set rates in the ICC: implied from the statute or expressly in the statute.
The Supreme Court in Interstate Commerce Commission v. Cincinnati found that nowhere in the statute is the Interstate Commerce Commission expressively given power to establish rates. The Supreme Court in Interstate Commerce Commission v. Cincinnati went onto say that the powers granted by the terms of the local law were solely administrative and executive, but not legislative. Because of this, without explicit grants of the power to establish rates by Congress, the ICC was not able to set rates for rail transport.
