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{{Copyedit|date=January 2014}}
{{Use mdy dates|date=September 2023}}
{{Infobox SCOTUS case
{{Infobox SCOTUS case
|Litigants=Smyth v. Ames
|Litigants=Smyth v. Ames
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|USVol=171
|USVol=171
|USPage=361
|USPage=361
|Citation=18 S. Ct. 888; 43 L. Ed. 197; 1898 U.S. LEXIS 1608
|ParallelCitations=18 S. Ct. 888; 43 [[L. Ed.]] 197; 1898 [[U.S. LEXIS]] 1608
|Prior=
|Prior=
|Subsequent=[[Federal Power Commission v. Hope Natural Gas Co.]]
|Subsequent=
|Holding=Voided [[Nebraska]] railroad tariffs and defined the constitutional limits of governmental power to set railroad and utility rates.
|Holding=Voided [[Nebraska]] railroad tariffs and defined the constitutional limits of governmental power to set railroad and utility rates.
|SCOTUS=1898–1902
|Majority=Harlan
|Majority=Harlan
|JoinMajority=
|JoinMajority=
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|JoinDissent2=
|JoinDissent2=
|LawsApplied=[[Fourteenth Amendment to the United States Constitution]], [[Contract Clause]]
|LawsApplied=[[Fourteenth Amendment to the United States Constitution]], [[Contract Clause]]
|Overruled={{ussc|name=Federal Power Commission v. Hope Natural Gas Co.|volume=320|page=591|year=1944}}
}}
}}


'''''Smyth v. Ames''''', [[case citation|171 U.S. 361]] (1898), also called '''''The Maximum Freight Case''''', was an 1898 United States [[United States Supreme Court|Supreme Court]] [[List of United States Supreme Court cases|case]].<ref name="justia">{{ussc|Source=f|171|361|1898}}</ref> The Supreme Court voided a [[Nebraska]] railroad tariff law, declaring that it violated the [[Fourteenth Amendment to the United States Constitution]] in that it takes property without the due process of law.<ref name="public-opinion">{{cite book
'''''Smyth v. Ames''''', 171 U.S. 361 (1898), also called '''''The Maximum Freight Case''''', was an 1898 United States [[United States Supreme Court|Supreme Court]] [[List of United States Supreme Court cases|case]].<ref name="justia">{{ussc|name=Smyth v. Ames|171|361|1898}}.</ref> The Supreme Court voided a [[Nebraska]] railroad tariff law, declaring that it violated the [[Fourteenth Amendment to the United States Constitution]] in that it takes property without the due process of law.<ref name="public-opinion">{{cite book
| title = Public Opinion: A Comprehensive Summary of the Press Throughout the World on All Important Current Topics
| title = Public Opinion: A Comprehensive Summary of the Press Throughout the World on All Important Current Topics
| publisher = Public Opinion Co. (Princeton University)
| publisher = Public Opinion Co. (Princeton University)
| year = 1898
| year = 1898
| pages = 330
| pages = 330
| url = http://books.google.com/?id=Y94aAAAAYAAJ&pg=PA330&dq=the+nebraska+maximum+decision
| url = https://books.google.com/books?id=Y94aAAAAYAAJ&q=the+nebraska+maximum+decision&pg=PA330
| isbn = }}</ref> The Court defined the constitutional limits of governmental power to set railroad and utility rates by stating that regulated industries have the right to a "fair return". The ruling was later overturned in ''[[Federal Power Commission v. Hope Natural Gas Co.]]''<ref name="answers">Siegel, Stephen A. [http://www.answers.com/topic/smyth-v-ames Smyth v. Ames]. [[Answers.com]]. Accessed 18 February 2009</ref>
}}</ref> The Court defined the constitutional limits of governmental power to set railroad and utility rates by stating that regulated industries have the right to a "fair return". The ruling was later overturned in ''[[Federal Power Commission v. Hope Natural Gas Co.]]''<ref name=Hope>{{ussc|name=Federal Power Commission v. Hope Natural Gas Co.|volume=320|page=591|year=1944}}.</ref><ref name="answers">Siegel, Stephen A. [http://www.answers.com/topic/smyth-v-ames Smyth v. Ames]. [[Answers.com]]. Accessed 18 February 2009</ref>


The decision was unanimous and the majority opinion was written by Justice [[John M. Harlan]].
The decision was unanimous and the majority opinion was written by Justice [[John M. Harlan]].
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| publisher = [[NYT]]
| publisher = [[NYT]]
| date = 8 March 1898
| date = 8 March 1898
| url = http://query.nytimes.com/mem/archive-free/pdf?res=9F00E3D61E3DE433A2575BC0A9659C94699ED7CF
| url = https://timesmachine.nytimes.com/timesmachine/1898/03/08/102489453.pdf
| accessdate = 18 February 2009
| access-date = 18 February 2009
}}
| format=PDF}}
</ref> Nebraska passed a law, a so-called "maximum rate bill", establishing maximum rates for the transportation of freights within the state.<ref name="public-opinion" /> The [[Railroad Commissioners of Nebraska]] were empowered to reduce any freight rate.<ref name="nebraska-law" />
</ref> Nebraska passed a law, a so-called "maximum rate bill", establishing maximum rates for the transportation of freights within the state.<ref name="public-opinion" /> The [[Railroad Commissioners of Nebraska]] were empowered to reduce any freight rate.<ref name="nebraska-law" />


Several precedents had been set by the Supreme Court regarding state control over railways. Until ''[[Munn v. Illinois]]'' when the [[Granger Laws]] were declared constitutional, it had been held that railway property was protected from state authority by the [[Contract Clause]] of the Constitution, which states that no state shall pass any "Law impairing the Obligation of Contracts". However, in the Munn case, the Court ruled that all property was held subject to legislative regulation if it was "affected with a public interest". Further decisions built off the Munn decision, specifying that while the legislature may regulate property "affected by the public interest", they must exercise it reasonably, so as to not deprive citizens of their property without [[due process]] of law.<ref name="central-law">{{cite journal
Several precedents had been set by the Supreme Court regarding state control over railways. Until ''[[Munn v. Illinois]]'' when the [[Granger Laws]] were declared constitutional, it had been held that railway property was protected from state authority by the [[Contract Clause]] of the Constitution, which states that no state shall pass any "Law impairing the Obligation of Contracts". However, in the Munn case, the Court ruled that all property was held subject to legislative regulation if it was "affected with a public interest". Further decisions built off the Munn decision, specifying that while the legislature may regulate property "affected by the public interest", they must exercise it reasonably by applying the [[Used and Useful Principle|used and useful principle]], so as to not deprive citizens of their property without [[due process]] of law.<ref name="central-law">{{cite journal
⚫
| title = The central law journal| journal = The Central Law Journal
| title =
⚫
The central law journal| journal = The Central Law Journal
| volume = 46
| volume = 46
| issue = 24
| issue = 24
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| location = St. Louis, MO
| location = St. Louis, MO
| date = 10 June 1898
| date = 10 June 1898
| url = http://books.google.com/?id=3HotAAAAIAAJ&pg=PA489&dq=the+nebraska+maximum+decision
| url = https://books.google.com/books?id=3HotAAAAIAAJ&q=the+nebraska+maximum+decision&pg=PA489
| accessdate = 18 February 2009}}
| access-date = 18 February 2009}}
</ref>
</ref>


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| year = 1899
| year = 1899
| pages = 545
| pages = 545
| url = http://books.google.com/?id=jJ8YAAAAIAAJ&pg=PA545&lpg=PA545&dq=%22Maximum+Freight+Case
| url = https://books.google.com/books?id=jJ8YAAAAIAAJ&q=%22Maximum+Freight+Case&pg=PA545
| last1 = Colby
⚫
}}</ref>
| first1 = Frank Moore
⚫
}}</ref>


The Supreme Court unanimously found the law unconstitutional. The court found that it is not enough to show a tariff – even if the tax is in the public interest – still leaves a company enough money to pay operating expenses and stock dividends.<ref name="the-nation">{{cite book
The Supreme Court unanimously found the law unconstitutional. The court found that it is not enough to show a tariff – even if the tax is in the public interest – still leaves a company enough money to pay operating expenses and stock dividends.<ref name="the-nation">{{cite book
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| year = 1898
| year = 1898
| pages = 261
| pages = 261
| url = http://books.google.com/?id=AQQDAAAAIAAJ&pg=PA260&dq=the+nebraska+maximum+decision
| url = https://books.google.com/books?id=AQQDAAAAIAAJ&q=the+nebraska+maximum+decision&pg=PA260
}}
}}
</ref>
</ref>
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| publisher = [[NYT]]
| publisher = [[NYT]]
| date = 9 March 1898
| date = 9 March 1898
| url = http://query.nytimes.com/mem/archive-free/pdf?res=9D0DE5D6123CE433A2575AC0A9659C94699ED7CF
| url = https://timesmachine.nytimes.com/timesmachine/1898/03/09/102549281.pdf
| accessdate = 18 February 2009
| access-date = 18 February 2009
}}
| format=PDF}}
</ref> Others were unhappy.<ref name="review">{{cite book
</ref> Others were unhappy.<ref name="review">{{cite book
| last = Shaw
| last = Shaw
| first = Albert
| first = Albert
| authorlink =
| coauthors =
| title = Review of Reviews and World's Work: An International Magazine
| title = Review of Reviews and World's Work: An International Magazine
| publisher = The Review of Reviews Corporation,
| publisher = The Review of Reviews Corporation
| year = 1898
| year = 1898
| pages = 402
| pages = 402
| url = http://books.google.com/?id=INUXpnp5etYC&pg=RA7-PA402&dq=the+nebraska+maximum+decision
| url = https://books.google.com/books?id=INUXpnp5etYC&q=the+nebraska+maximum+decision&pg=RA7-PA402
}}</ref>
}}</ref>


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| last = Myers
| last = Myers
| first = Gustavus
| first = Gustavus
| authorlink =
| coauthors =
| title = History of the Supreme Court of the United States
| title = History of the Supreme Court of the United States
| publisher = C. H. Kerr
| publisher = C. H. Kerr
| year = 1912
| year = 1912
| pages = 637
| pages = 637
| url = http://books.google.com/?id=Mt89AAAAIAAJ&pg=PA637&lpg=PA637&dq=nebraska+maximum+rate+supreme+court+case+interstate+commerce+commission
| url = https://books.google.com/books?id=Mt89AAAAIAAJ&q=nebraska+maximum+rate+supreme+court+case+interstate+commerce+commission&pg=PA637
}}</ref>
}}</ref>


==Subsequent history==
==Subsequent history==
The ruling was overturned in ''[[Federal Power Commission v. Hope Natural Gas Co.]]''<ref name="answers" />
The ruling was overturned in the 1944 case of ''[[Federal Power Commission v. Hope Natural Gas Co.]]''<ref name=Hope/><ref name="answers"/> The named plaintiff in the case, Nebraska Attorney General [[Constantine Joseph Smyth]], later served as Chief Justice of the [[United States Court of Appeals for the District of Columbia Circuit|Court of Appeals of the District of Columbia]].


==References==
==References==
{{reflist}}
{{reflist}}


==External links==
* {{caselaw source
| case = ''Smyth v. Ames,'' {{ussc|171|361|1898|el=no}}
| courtlistener =https://www.courtlistener.com/opinion/94919/smyth-v-ames/
| findlaw = https://caselaw.findlaw.com/us-supreme-court/171/361.html
| googlescholar = https://scholar.google.com/scholar_case?case=2775937942756134199
| justia =https://supreme.justia.com/cases/federal/us/171/361/
| loc =http://cdn.loc.gov/service/ll/usrep/usrep171/usrep171361/usrep171361.pdf
}}

{{USArticleI}}

[[Category:United States Constitution Article One case law]]
[[Category:United States Supreme Court cases]]
[[Category:United States Supreme Court cases]]
[[Category:United States Supreme Court cases of the Fuller Court]]
[[Category:1898 in United States case law]]
[[Category:1898 in United States case law]]
[[Category:Legal history of Nebraska]]
[[Category:Legal history of Nebraska]]
[[Category:Contract Clause case law]]
[[Category:Contract Clause case law]]
[[Category:Rail transportation in Nebraska]]

Revision as of 03:05, 13 September 2023

Smyth v. Ames
Supreme Court of the United States
Submitted May 9, 1898
Decided May 31, 1898
Full case nameSmyth, Attorney General, et al. v. Ames, et al.; Smyth, Attorney General, et al. v. Smith, et al.; Smyth, Attorney General, et al. v. Higginson, et al.
Citations171 U.S. 361 (more)
18 S. Ct. 888; 43 L. Ed. 197; 1898 U.S. LEXIS 1608
Holding
Voided Nebraska railroad tariffs and defined the constitutional limits of governmental power to set railroad and utility rates.
Court membership
Chief Justice
Melville Fuller
Associate Justices
John M. Harlan · Horace Gray
David J. Brewer · Henry B. Brown
George Shiras Jr. · Edward D. White
Rufus W. Peckham · Joseph McKenna
Case opinion
MajorityHarlan
Laws applied
Fourteenth Amendment to the United States Constitution, Contract Clause
Overruled by
Federal Power Commission v. Hope Natural Gas Co., 320 U.S. 591 (1944)

Smyth v. Ames, 171 U.S. 361 (1898), also called The Maximum Freight Case, was an 1898 United States Supreme Court case.[1] The Supreme Court voided a Nebraska railroad tariff law, declaring that it violated the Fourteenth Amendment to the United States Constitution in that it takes property without the due process of law.[2] The Court defined the constitutional limits of governmental power to set railroad and utility rates by stating that regulated industries have the right to a "fair return". The ruling was later overturned in Federal Power Commission v. Hope Natural Gas Co.[3][4]

The decision was unanimous and the majority opinion was written by Justice John M. Harlan.

Prior history

On April 12, 1893,[5] Nebraska passed a law, a so-called "maximum rate bill", establishing maximum rates for the transportation of freights within the state.[2] The Railroad Commissioners of Nebraska were empowered to reduce any freight rate.[5]

Several precedents had been set by the Supreme Court regarding state control over railways. Until Munn v. Illinois when the Granger Laws were declared constitutional, it had been held that railway property was protected from state authority by the Contract Clause of the Constitution, which states that no state shall pass any "Law impairing the Obligation of Contracts". However, in the Munn case, the Court ruled that all property was held subject to legislative regulation if it was "affected with a public interest". Further decisions built off the Munn decision, specifying that while the legislature may regulate property "affected by the public interest", they must exercise it reasonably by applying the used and useful principle, so as to not deprive citizens of their property without due process of law.[6]

Case

The maximum rate law was contested by the Union Pacific, St. Joseph and Grand Island Railway, Omaha and Republican Valley Railway, and the Kansas City and Omaha Railway. They claimed the law was confiscation, and therefore unconstitutional.[5] They said the law would make a difference of $2,250,00 annually.[7]

The Supreme Court unanimously found the law unconstitutional. The court found that it is not enough to show a tariff – even if the tax is in the public interest – still leaves a company enough money to pay operating expenses and stock dividends.[8]

Effects of the decision

Businessmen were pleased by the decision, and believed it would give stability to railroad investments.[9] Others were unhappy.[10]

The Interstate Commerce Commission was weakened by the Court's decision.[11]

Subsequent history

The ruling was overturned in the 1944 case of Federal Power Commission v. Hope Natural Gas Co.[3][4] The named plaintiff in the case, Nebraska Attorney General Constantine Joseph Smyth, later served as Chief Justice of the Court of Appeals of the District of Columbia.

References

  1. ^ Smyth v. Ames, 171 U.S. 361 (1898).
  2. ^ a b Public Opinion: A Comprehensive Summary of the Press Throughout the World on All Important Current Topics. Public Opinion Co. (Princeton University). 1898. p. 330.
  3. ^ a b Federal Power Commission v. Hope Natural Gas Co., 320 U.S. 591 (1944).
  4. ^ a b Siegel, Stephen A. Smyth v. Ames. Answers.com. Accessed 18 February 2009
  5. ^ a b c "Nebraska Law Invalid" (PDF). NYT. March 8, 1898. Retrieved February 18, 2009.
  6. ^ "The central law journal". The Central Law Journal. 46 (24). St. Louis, MO: Soule, Thomas & Wentworth: 489. June 10, 1898. Retrieved February 18, 2009.
  7. ^ Colby, Frank Moore (1899). The International Year Book. p. 545.
  8. ^ The Nation. J.H. Richards. 1898. p. 261.
  9. ^ "Maximum Rate Decision" (PDF). NYT. March 9, 1898. Retrieved February 18, 2009.
  10. ^ Shaw, Albert (1898). Review of Reviews and World's Work: An International Magazine. The Review of Reviews Corporation. p. 402.
  11. ^ Myers, Gustavus (1912). History of the Supreme Court of the United States. C. H. Kerr. p. 637.
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