Chicago, Minn. & St. Paul Ry. Co. v. Minnesota
Case Date: 12/31/1969
Docket No: none
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A Minnesota law made its railroad commission the final judge of the reasonableness of railroad rates. The railroad maintained that "it is always a judicial question as to whether a statute is repugnant to provisions of the constitution." QuestionDoes the Minnesota law violate the due process clause of the 14th Amendment? ConclusionYes. The statute did not provide procedural due process: railroads received no hearing or other chance to defend their rates before the commission. Moreover, a rate's reasonableness "is eminently a question for judicial investigation, requiring due process of law for its determination." A company denied the authority to charge a reasonable rate and unable to turn to a judicial mechanism for review would be deprived of the "lawful use of its property, and, thus, in substance, and effect, of the property without due process of law." |