Stone v. Farmers' Loan & Trust Co.

Headnotes

1. Constitutional Law — Contracts Clause A State has the power to reasonably limit the amount of charges by a railroad company for the transportation of persons and property within its jurisdiction unless restrained by some contract in the charter; this power of regulation is a continuing governmental power that can be bargained away only by words of positive grant or their equivalent, and if there is reasonable doubt as to whether it has been surrendered, the doubt must be resolved in favor of the existence of the power. 116 U.S. at 321–22
2. Constitutional Law — Contracts Clause A charter provision authorizing a railroad company "from time to time to fix, regulate, and receive the tolls and charges" for transportation grants power to fix reasonable charges but does not surrender the State's power to declare what shall be deemed reasonable, nor exempt the company from legislative regulation of rates; the power to charge being coupled with the condition that the charge be reasonable, the State remains free to act on the subject of reasonableness within the limits of its general authority. 116 U.S. at 325–26
3. Constitutional Law — Contracts Clause A charter provision conferring on the directors power to make by-laws, rules, and regulations touching the management of the company's property "not contrary to the laws of this State" includes laws in force when the charter was granted and those enacted afterwards, and implies no contract exempting the company from the operation of laws enacted within the scope of legislative power. 116 U.S. at 324
4. Constitutional Law — Contracts Clause The State's power to regulate railroad charges is not a power to destroy, and limitation is not the equivalent of confiscation; under the pretense of regulating fares and freights, the State may not require a railroad corporation to carry persons or property without reward, nor act so as to amount to a taking of private property for public use without just compensation or without due process of law. 116 U.S. at 331
5. Constitutional Law — State Regulation of Railroads A railroad forming a continuous line in two or more States, owned and managed by a corporation deriving its powers from the legislature of each State in which the road lies, is as to domestic traffic in each State a domestic corporation of that State, and the State may regulate freights and fares for business done exclusively within it and enact police regulations for the comfort, convenience, and safety of travelers; state legislation on the subject is unconstitutional only when it necessarily amounts to or operates as a regulation of business without the State as well as within it, or burdens interstate business. 116 U.S. at 334–35
6. Constitutional Law — Equal Protection General statutes regulating the use of railroads in a State, or fixing maximum rates of charges for transportation, when not forbidden by charter contracts, do not necessarily deprive a railroad corporation of its property without due process of law or deny it the equal protection of the laws, where the statute applies equally to all persons and corporations owning or operating railroads in the State and gives no preference to one over another. 116 U.S. at 334
7. Constitutional Law — Separation of Powers A state statute creating a railroad commission and charging it with the duty of supervising railroads is not in conflict with a state constitution that divides governmental powers among three departments, where the commission's functions relate to the supervision of the administration of domestic corporations. 116 U.S. at 332
8. Statutory Interpretation — Validity — Uncertainty A statute creating a railroad commission and regulating rates is not so inconsistent and uncertain as to be void on its face; the possibility that particular provisions may prove invalid when applied does not render the entire act inoperative where the commission has not yet acted and the validity of specific enforcement proceedings remains open for future consideration. 116 U.S. at 335–36