Joseph Rucker Lamar

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.

procedurefederal power

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.

business & regulatoryproperty

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.

business & regulatoryfederal power

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.

procedureproperty

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.

labor & employmentfederal powertorts & liability

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.

procedure

The case involved a railroad employee, Ferebee, who sued his employer, Norfolk Southern Railroad, under the Federal Employers’ Liability Act for personal injuries sustained when he stepped off a train car with missing steps. The railroad defended by alleging contributory negligence by the plaintiff. After a state trial court found the railroad negligent and the plaintiff not contributorily negligent, the North Carolina Supreme Court granted a partial new trial limited to damages; a second jury awarded damages without reconsidering contributory negligence or mitigation. The U.S. Supreme Court affirmed, holding that while federal substantive rights under the Act cannot be impaired by state procedural rules, the issues of liability and damages were separable in this instance because the plaintiff’s conduct did not affect the damage award. The Court noted that partial new trials are generally disfavored in FELA cases but were permissible here without depriving the defendant of a federal right.

labor & employmenttorts & liabilityprocedurefederal power

This case involved a brakeman injured while setting hand brakes on two cars being switched from an interstate freight train onto a siding in New York. The railroad contended that the work had become purely intrastate once the cars were uncoupled, so the Federal Employers’ Liability Act did not apply and recovery was barred by the state fellow-servant rule. The Supreme Court held that the employee remained engaged in interstate commerce because his duties were necessary to allow the interstate train to continue its journey. The Court therefore ruled that the FELA governed the claim and affirmed the judgment for the plaintiff.

labor & employmenttorts & liability

The case involved a 1897 Indiana judgment against Kreitlein for $300 arising from an unpaid flour sale, which Ferger sought to enforce in 1907 after Kreitlein received a 1905 bankruptcy discharge. Kreitlein introduced the discharge order as a defense, along with bankruptcy schedules listing Ferger's debt, while Ferger argued the judgment was not discharged due to lack of notice from improper scheduling and that the debt was non-provable. The Court held that a certified discharge order establishes a prima facie defense under the Bankruptcy Act, shifting the burden to the creditor to prove an exception, and that the debt remained provable even if arising from a trover action rather than contract. It further reasoned that the schedules provided sufficient notice despite any address imperfections, rejecting claims that the judgment fell outside the discharge's scope.

federal powerbusiness & regulatoryprocedure

The case concerned a dispute over a mutual assessment life insurance policy issued by Hartford Life Insurance Company to Herman Ibs. After Ibs failed to pay an assessment levied to replenish the Mortuary Fund and his policy was canceled, his widow sued in Minnesota state court, arguing the assessment was unnecessary and void because the fund already held sufficient money to cover claims. The company defended by pointing to a prior Connecticut court decree in a class action brought by other certificate holders that upheld the company's practices of advancing payments from the fund and later replenishing it through assessments. Minnesota courts excluded the decree on the ground that the widow was not a party to the Connecticut proceeding and entered judgment for her. The U.S. Supreme Court reversed, holding that the Connecticut decree was entitled to full faith and credit under the Constitution because it conclusively determined the company's authority over the fund in a proceeding binding on members and their beneficiaries.

business & regulatoryfederal powerprocedure

The case involved the Louisville & Nashville and Nashville, Chattanooga & St. Louis Railroad Companies challenging orders from the Interstate Commerce Commission that reduced the freight rate on coal from $1 to 80 cents per ton to Nashville and required the railroads to end a discriminatory switching practice in the Nashville yard by providing equal facilities to competing carriers. The railroads sued in federal district court to enjoin the orders, arguing that the Commission's findings did not legally support them, but the district court denied relief and the Supreme Court affirmed. The Court reasoned that the complainant had met its burden by showing through extensive rate comparisons that the existing rate was unreasonable, and that the Commission had authority under the statute to prohibit discrimination in switching services without improperly requiring affirmative use of the railroads' property.

business & regulatoryfederal power

The case concerned whether a customs collector could, after one year, reliquidate duties on imported goods based on a finding of fraud and require the importer to pay the additional amount within 15 days to challenge that finding or the new assessment. The Court reviewed the Tariff Act of 1909 and the 1874 statute on customs settlements, noting that liquidation is normally final after one year absent fraud and that initial assessments require payment before protest or appeal to the Board of General Appraisers. It held that a post-year reliquidation due to alleged fraud does not bind the importer without a hearing, and in a subsequent collection suit the importer may defend on the merits, including contesting the fraud claim and the duty amount, with the government required to follow ordinary pleading rules to prove fraud.

business & regulatoryfederal powertaxesprocedure

The case involved the Pennsylvania Railroad, an interstate carrier, being sued by the Puritan Coal Mining Company for damages due to failure to provide sufficient rail cars for coal shipments and for discriminatory distribution of cars during shortages, violating both common law duties and a state statute. The trial court and Pennsylvania Supreme Court awarded damages to the plaintiff. The U.S. Supreme Court affirmed, holding that state courts had concurrent jurisdiction over the claim for damages from unjust discrimination and failure to furnish cars without requiring a prior determination by the Interstate Commerce Commission, as the Commerce Act preserved existing remedies in state courts alongside federal options.

business & regulatoryfederal powerprocedure

The case Chapman v. Zobelein concerned the validity of a California tax sale procedure applied to a Los Angeles lot assessed at $1.80, sold to the state in 1899 for unpaid taxes, and then resold in 1905 to Zobelein for $166 after the five-year redemption period expired. Chapman, claiming ownership, filed suit to quiet title and cancel the deed, contending that selling the full lot (worth $500) without offering only a portion sufficient to cover taxes deprived him of property without due process. The Supreme Court affirmed the dismissal of the bill, holding that the statutory scheme satisfied constitutional requirements. Its reasoning emphasized that the laws afforded an opportunity to contest the assessment before the Board of Equalizers, published notice of the initial sale to the state, a five-year redemption window, and further public and mailed notice before the second sale to the highest bidder.

taxesproperty

The case involved the Littlefield Cattle Company suing railroads operating the Santa Fe system for damages after the railroads failed to provide promised rail cars for shipping cattle from Texas to Missouri in 1907, forcing the company to hold and return the herd at significant loss. The railroads argued that state courts lacked jurisdiction because the claim arose under federal commerce law and that a car shortage excused their failure. The Supreme Court dismissed the writ of error, holding that state courts have jurisdiction over such damage claims under the Commerce Act's proviso, and that the railroads could not rely on the shortage defense without having promptly notified the shipper of their inability to fulfill the order when accepted.

business & regulatoryfederal powerprocedure

The case involved whether a federal district court had jurisdiction over a lawsuit brought on a supersedeas bond that was posted to stay a federal judgment pending appeal, where the parties were not citizens of different states. The Supreme Court affirmed the district court's jurisdiction, holding that the suit arose under the laws of the United States. The reasoning was that federal statutes authorized the bond for appeals and created the right of action on the bond upon affirmance of the judgment, distinguishing it from ordinary contracts or the underlying common-law claim.

federal powerprocedure

The case involved a Michigan lumber manufacturer that sued several railroads to recover alleged overcharges on shipments from Alabama, claiming the 2-cent rate increase was unreasonable based on an Interstate Commerce Commission finding in a proceeding brought by a trade association. The plaintiff had not participated in the Commission case or filed its own claim for reparation within the required period. The Supreme Court held that while the Commission's general finding on rate reasonableness inured to the benefit of all shippers, any claim for refund had to be asserted within the statutory time limit under the Commerce Act. Because the suit was filed more than four years after the overcharges, the statute of limitations barred recovery and destroyed the underlying liability. The Court affirmed dismissal of the action, emphasizing the need for uniformity and nondiscrimination among shippers.

business & regulatoryfederal powerprocedure

The case concerned whether a 1909 presidential proclamation withdrawing millions of acres of public oil lands in California and Wyoming from private entry and location was valid, after Midwest Oil Company located claims and extracted oil from withdrawn Wyoming land. The government sued to recover the land and oil proceeds, but lower courts dismissed the suit. The Supreme Court held the withdrawal valid, reasoning that longstanding executive practice of issuing similar land withdrawals, combined with Congress's repeated tacit recognition of that authority in statutes dealing with public lands, supported the President's power to act in the public interest pending legislation.

federal powerpropertyenvironment

The case involved an Indiana state law requiring railroads to equip cars with secure grab-irons and hand-holds, under which the state Railroad Commission sued Southern Railway Company for transporting a non-compliant car within the state. The company argued it was not liable under state law because the federal Safety Appliance Act already regulated the same equipment and penalties for cars on interstate railroads. The Supreme Court reversed the judgment against the company, holding that Congress had occupied the field of regulating safety appliances on freight cars used in interstate commerce. The Court reasoned that the federal power to regulate interstate commerce is exclusive once exercised, superseding any state legislation on the same subject even if the state rules were not in direct conflict or sought to supplement federal requirements.

federal powerbusiness & regulatory

The case involved a dispute over cotton sold by Lehman, Stern & Co. to Martin & Co., where the buyers' checks were dishonored, prompting the sellers to sue in Louisiana state court for the purchase price and to enforce a statutory vendor's lien via writs of attachment and garnishment on the cotton held by third parties. Shortly after the suit began, Martin & Co. were adjudicated bankrupts, and a receiver intervened to challenge the state court's jurisdiction. The Louisiana Supreme Court issued a writ of prohibition barring the state trial court from proceeding to enforce the lien, ruling that the garnishment did not give the court possession of the cotton and that the Bankruptcy Act dissolved the attachment lien. The U.S. Supreme Court affirmed, holding that state law required possession for lien enforcement and that federal bankruptcy provisions eliminated the attachment-based lien, leaving the matter for the bankruptcy court. The decision rested on the interplay between Louisiana property and procedure rules and section 67f of the Bankruptcy Act.

federal powerpropertyprocedurebusiness & regulatory