The case concerned whether a private citizen could use quo warranto proceedings under the District of Columbia Code to challenge an incumbent's title to a federal public office without approval from the Attorney General or District Attorney. Frizzell, a citizen and taxpayer with no claim to the office of Civil Commissioner, sought to oust Newman after those officers declined to act. The Supreme Court held that the Code treats usurpation of office as a public wrong redressable only by the government or by a qualifying "interested person" who has a direct stake, such as a prior incumbent or claimant to the office; a mere citizen or taxpayer does not qualify. Because Frizzell lacked such an interest, the lower court had no authority to permit him to proceed in the name of the United States. The judgment was reversed with instructions to dismiss the action.
The case involved a challenge to a 1911 Wisconsin statute that prohibited sleeping car companies from lowering an upper berth until it was engaged or occupied by a passenger. The Supreme Court reversed the state supreme court's decision upholding the law, holding that the statute violated the Due Process Clause by taking the company's property without compensation. The core reasoning was that the regulation was not a valid exercise of police power as a health measure, since lowering upper berths did not endanger health or safety, and it improperly compelled the railroad to provide free use of salable space that remained its property even when unused.
The case concerned whether the Delaware, Lackawanna and Western Railroad violated the Commodity Clause of the Hepburn Act by transporting coal in interstate commerce after arranging to sell it at the mine mouth to a Coal Company that shared the same officers, stockholders, and management. The District Court had dismissed the government's suit, finding the stock overlap illegal but the sales contract lawful. The Supreme Court reversed, holding that the contract was invalid because the Railroad retained indirect interest and control over the coal and the buyer, effectively making the Coal Company a puppet rather than an independent purchaser. The Court reasoned that the Clause requires railroads to fully dissociate from any direct or indirect interest in commodities before transportation begins, and that common management plus restrictive contract terms preventing the buyer from acting freely meant the arrangement did not achieve the statutory separation of carrier and shipper roles.
The case concerned a dispute between an express carrier and a consignor over liability for a ring shipped C.O.D. that was seized via a replevin action filed by the consignee in an Illinois municipal court. The Texas trial court held the carrier liable for the value of the goods, and the U.S. Supreme Court affirmed. The Court reasoned that although a carrier is not liable for goods taken by valid judicial process, it must first give the consignor prompt notice of the suit so the consignor can defend; here the carrier's mailed notice, sent only two days before trial and not received until after judgment, was inadequate. The Illinois judgment was treated as valid but unavailable as a defense because the carrier failed to prove the required notice element.
The case involved the death of brakeman Enoch L. White in a rear-end train collision on an interstate railroad, where his administratrix sued the Central Vermont Railway under the Federal Employers' Liability Act for the benefit of his widow and minor children, resulting in a $7,168 jury verdict. The Supreme Court affirmed the judgment, holding that the federal statute governed key issues including the burden of proof on contributory negligence (which rested on the defendant) and that the evidence sufficiently showed the company's negligence through a clearance card and a leaking cylinder that obscured visibility. The Court reasoned that the Act superseded conflicting state rules on substantive matters like contributory negligence and did not require the jury to apportion damages among beneficiaries, as that was not mandated by the federal law and was a matter for probate courts. Other assignments of error, such as assumption of risk and certain evidentiary rulings, were rejected as unsupported by the facts or not raising federal questions.
The case involved a dispute over attorneys' fees in which Pless & Winbourne sued McDonald and obtained a jury verdict for $2,916. McDonald moved to set aside the verdict on the ground that it was reached by an improper quotient method in which jurors averaged proposed amounts, and he sought to introduce a juror's testimony to prove the alleged misconduct. The Supreme Court held that a juror is incompetent to impeach the verdict, affirming the lower courts' refusal to admit such testimony. The Court reasoned that public policy favors protecting the privacy of jury deliberations over redressing potential private injuries, to avoid harassment of jurors and erosion of candid discussion, and that the Conformity Act does not govern this self-preservation rule of the federal courts.
