United States V. Interstate Commerce Commission - Decision

Decision

Associate Justice Hugo Black, joined by Chief Justice Fred M. Vinson and Associate Justices Reed, Douglas, Murphy, and Rutledge delivered the opinion of the Court. In brief, the Court ruled that the District Court's decision to dismiss the Government's complaint was improper, and ordered the dismissal reversed, remanding the complaint back to the lower court for a hearing based on the case's merits.

In the matter of whether this case, at one point referred to as "United States v. United States, et al.," was a violation of the long-standing theory that a group cannot sue itself, the Court declared that the line of reasoning presented was improper. The Court stated that the defendant's position relied too heavily on mere nomenclature rather than the facts of the case at hand. The opinion presents an analogy for comparison; John Smith suing himself presents no controversy that a court may rule upon, but this same John Smith might indeed have a valid case to bring against another man also named John Smith. In the present case, the Court determined that the controversies involved are "traditionally justiciable," and that the Government, unless prevented by law, has the same right as any other shipper to seek the protection of the courts. This portion of the defendant's position was judged as untenable.

Regarding the defendant's argument that the language of the Interstate Commerce Act demonstrates a legislative intent to prevent the Government from disobeying decisions made by the Interstate Commerce Commission, the Court held that the defendant was in error. If this argument was to be accepted, the Court reasoned, Congress would have been intentionally forcing the United States (as a shipper) to give up the power of self-protection that is enjoyed by every other shipper. The appearance of the Attorney General on both sides of the case was merely a function of the duties of his position rather than a necessary demonstration of the impossibility of suit.

On the issue of the Government's inability to bring suit in a court after having unsuccessfully made a complaint with the ICC, the Court determined that forbidding judicial review in this manner was "out of harmony with the general legislative pattern of administrative and judicial relationships." The Court stated that the defendant's position on this matter was unacceptable. The opinion remarked that, by this argument, "the order is final and not reviewable by any court, even though entered arbitrarily, without substantial evidence, and in defiance of law." Such a position was deemed inappropriate, and this argument was rejected.

In the final points, the Court found that a judicial review of the type brought by the Government against the railroads did not require a three-judge panel to make a ruling; rather, a single judge was the most appropriate course. In accordance with the other points the Court adopted, it declared that, because the District Court did not hear the case based on the merits of the complaint, it was appropriate to reverse the decision of the lower court and remand the case back for such judgment.