Southern Pacific Co. v. Arizona ex rel. Sullivan (1940)
- Docket
- 56
- Decided
- 1940-1955-
Summary
Question: Did the Arizona law violate the Commerce Clause? Conclusion: In an opinion authored by Justice Harlan F. Stone, the plurality struck down the law. The Court reasoned that that the law imposed a great burden on interstate commerce because nearly all the freight and passenger rail traffic in Arizona was interstate traffic, meaning that even trains operating outside Arizona had to comply with the law. As a result, 30% more trains than previously used were needed because of the limitation on the number of trains per car, at an added cost of $1,000,000 per year before adjustment for inflation. The Court found that there was insufficient benefit to Arizona's legitimate health and safety interests to justify so great a burden on interstate commerce. The law had ostensibly been passed to decrease the rate of rail accidents that "result from the greater length of trains," but the court noted that if anything the result of the law might have been to increase accidents "resulting from the larger number of trains." Accordingly, the law was not reasonably related to the state's legitimate interest in train safety let alone sufficiently beneficial towards achieving that end that it would justify the burden it imposed on interstate commerce. Justice Rutledge concurred. Justices Black and Douglas dissented.