Southern Railway Co. v. United States

Southern Railway Company v. United States, 222 U.S. 20 (1911), was a decision by the United States Supreme Court which held that under the Commerce Clause, the U.S. Congress can regulate safety on intrastate rail traffic because there is a close and substantial connection to interstate traffic.

Southern Railway Company v. United States
Supreme Court of the United States
Argued March 9–10, 1911 Decided October 30, 1911
Full case name	Southern Railway Company, Plaintiff in Error, v. United States
Citations	222 U.S. 20 (more) 32 S. Ct. 2; 56 L. Ed. 72; 1911 U.S. LEXIS 1875
Holding
The Court held that under the Commerce Clause, the U.S. Congress can regulate safety on intrastate rail traffic because there is a close and substantial connection to interstate traffic.
Court membership
Chief Justice Edward D. White Associate Justices Joseph McKenna · Oliver W. Holmes Jr. William R. Day · Horace H. Lurton Charles E. Hughes · Willis Van Devanter Joseph R. Lamar
Case opinion
Majority	Van Devanter, joined by Unanimous
Laws applied
Safety Appliance Act, Commerce Clause

Background

Congress required all train cars to be equipped with couplers as a safety measure. Southern Railway argued that the requirement applied only to train cars crossing state lines, not to train cars that operated inside one state.

The Safety Appliance Act of March 2, 1893, 27 Stat. 531, c. 196:

...imposed upon every carrier "engaged in interstate commerce by railroad" the duty of equipping all trains, locomotives, and cars used on its line of railroad in moving interstate traffic, with designated appliances calculated to promote the safety of that traffic...

Decision

The Commerce Clause is plenary to protect persons and property moving in interstate commerce from all danger. No matter the source or destination, Congress may require all vehicles moving on lanes of interstate commerce to be so equipped with safety devices to avoid danger to persons and property in interstate commerce.

See also

• Henderson v. United States
• List of United States Supreme Court cases, volume 222

External links

• Text of Southern Railway Co. v. United States, 222 U.S. 20 (1911) is available from: Cornell CourtListener Findlaw Google Scholar Justia Library of Congress