United States v. California

Headnotes

1. Constitutional Law — Common Carrier Status Whether a transportation agency is a common carrier depends not upon its corporate character or declared purposes, but upon what it does. 297 U.S. at 181
2. Constitutional Law — Commerce Clause A state-owned railroad that receives and transports, for the public and for hire, all freight cars, loaded and empty, offered to it by connecting railroads, industrial plants, and steamships, at a flat rate per car, where the larger part of such traffic has its origin or destination in other states, is a common carrier engaged in interstate commerce, even though it maintains no freight station, issues no bills of lading, and is not a party to through rates. 297 U.S. at 182
3. Constitutional Law — State Sovereignty A state, in operating a common-carrier railroad in interstate transportation — even where the purpose is to facilitate the commerce of a port and the net proceeds are used for harbor improvement — acts in subordination to the power of Congress under the Commerce Clause. 297 U.S. at 183
4. Constitutional Law — Federal Supremacy Even if a state, in conducting its railroad, be said to act in its sovereign rather than private capacity, its sovereignty in that regard is necessarily diminished to the extent of the power granted by the Constitution to the federal government. 297 U.S. at 183
5. Constitutional Law — Commerce Clause The principle by which state instrumentalities are protected from federal taxation, and vice versa, is inapplicable by analogy as a limitation upon the federal power to regulate interstate commerce; unlike the taxing power, the commerce power is plenary and is not restricted by the traditional activities of the states. 297 U.S. at 184
6. Labor & Employment Law — Safety Appliance Act The provisions of the Safety Appliance Act forbidding any common carrier engaged in interstate commerce by railroad to haul cars not equipped with prescribed couplers, and penalizing infractions, include state-owned interstate rail carriers; a state that engages in interstate commerce by rail subjects itself to the commerce power and is liable for a violation of the Act as are other carriers. 297 U.S. at 185
7. Statutory Interpretation — Sovereign Immunity from Statutes The canon of construction that a sovereign is presumptively not intended to be bound by its own statute unless named in it does not require that the aim of a statute fairly to be inferred be disregarded because not explicitly stated, and should not be extended so as to exempt from an Act of Congress a business plainly within its terms and purpose merely because the business is carried on by a state. 297 U.S. at 186
8. Federal Courts & Jurisdiction — Jurisdiction Although Article III extends the judicial power and the original jurisdiction of the Supreme Court to cases in which a state is a party, Congress may confer on inferior courts original jurisdiction of suits in which a state is a party. 297 U.S. at 187
9. Federal Courts & Jurisdiction — Jurisdiction — Statutory Construction Where the Safety Appliance Act provides that the penalty it imposes is to be recovered in a suit brought by the United States district attorney in the district court of the United States having jurisdiction in the locality where the violation was committed, that section, as the later enactment, supplants the earlier provision of the Judicial Code giving the Supreme Court exclusive jurisdiction of all controversies of a civil nature where a state is a party, and lodges jurisdiction in the district court of the locality, with respect to suits against states. 297 U.S. at 187