Mississippi Railroad Commission v. Illinois Central Railroad’s Empirical Analysis
203 U.S. 335 · 1906
Citation profile
14 federal appellate · 24 district · 36 state decisions
How this case has been cited
Cited by 180 later decisions (27 by the Supreme Court) — most recently May 2001 · most notably Ex Parte: Edward T Young (1908), Larson v. Domestic & Foreign Commerce Corp. (1949)
14 federal appellate · 24 district · 36 state decisions — followed in 13 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedIllinois Cent. R. Co. v. Mississippi Railroad Commission (from Fifth Circuit Court of Appeals)
Relationships
Relies on Smyth v. Ames · Reagan v. Farmers' Loan & Trust Co. · Lake Shore Ry Co v. State of Ohio Lawrence · Prout v. Starr · Field v. Barber Asphalt Paving Co.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 180 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The order cannot be viewed alone in the light of ordering a stop at one place only which might require only three minutes as asserted. It is a question whether these trains can be stopped at all at any particular station when proper and adequate facilities are otherwise afforded such station. If the commission can order such a train to be stopped at a particular locality under such circumstances, then it could do so as to other localities, and in that way the usefulness of a through train would be ruined, and the train turned from a through to a local one in Mississippi. The Legislature of a state could not itself make such an order, and it cannot delegate the power to a commission to do so in its discretion, when adequate facilities are otherwirse furnished. The transportation of passengers on interstate trains as rapidly as can with safety be done is the inexorable demand of the public who use such trains. Competition between great trunk lines is fierce and at times bit ter. Each line must do its best even to obtain its fair share of the transportation between states, both of passengers and freight. A wholly unnecessary, even though small, obstacle, ought not in fairness be placed in the way of an interstate road, which may thus be unable to meet the competition of its’rivals.””
2 later decisions quote this exact passage · from the majority“It is also objected that an injunction will not lie from a United States court to stay proceedings in a state court, because of the provisions of [the Anti-Injunction Act]. The [Mississippi Railroad] [Commission is, however, not a court, and is a mere administrative agency of the State, as held by the Mississippi court. It is urged, however, that proceedings in a state court were commenced by the presentation of the petition of the citizens of Magnolia to the railroad commission, and because the commission, having made an order to stop the trains, would have to resort to the proper state court to aid it in the enforcement of its order, therefore the whole proceeding must be regarded as in a state court from the commencement. Whatever may be the provision of the state statute in regard to the enforcement solely by the state court of the order of the railroad commission, the proceeding while before the commission never thereby became a proceeding in a state court, and the jurisdiction of the Federal court to enjoin the commission from the enforcement of its order, because such order was a violation of the Federal Constitution, was not in the least affected.”
1 later decision quote this exact passage · from the majority““Upon the principles decided in these cases, a state Railroad Commission has the right, under a state statute, so far as railroads are concerned, to compel a company to stop its trains under the circumstances already referred to, and it may order the stoppage of such trains if the company does not otherwise furnish proper and adequate accommodation to a particular locality, and in such cases the order may embrace a through, interstate train actually running and compel it to stop at a locality named.””
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.