Skip to main content

Granger Cases


GRANGER CASES. In the face of increasing activism calling for the regulation of railway rates by the Grangers (members of the National Grange of the Order of Patrons of Husbandry) and other groups, several Midwestern states asserted regulatory authority over the railroad industry, enacting what were known as the Granger Laws. Illinois's 1870 constitution called for the state legislature to "prevent unjust discrimination and extortion" in freight and passenger rates, and Illinois, along with Wisconsin, Iowa, and Minnesota moved to regulate railroads and warehouses within their borders. Most of the state laws were poorly drawn and were eventually appealed as the railroads created uniform rates by raising them to the maximum allowed by law.

Illinois's regulations were the strongest and became the subject of Munn v. Illinois (1877), the most important of the eight Granger Cases. Fourteen Chicago warehouses, including that of the Munn Brothers, stored the grain produced by seven states. In Munn v. Illinois, the Court was asked to determine whether the state could regulate a private industry that served a public function. In a 5 to 4 decision, the Court sided with Illinois and established the Public Interest Doctrine, declaring that states could properly regulate private entities that served a public function. Chief Justice Morrison R. Waite, writing for the Court, declared that when "one devotes his property to a use in which the public has an interest, he, in effect, grants to the public an interest in that use, and must submit to be controlled by the public for the public good." Nationwide, other states followed suit, and the movement eventually gave rise to federal regulatory entities such as the Interstate Commerce Commission.


Cashman, Sean Dennis. America in the Gilded Age: From the Death of Lincoln to the Rise of Theodore Roosevelt. New York: New York University Press, 1993.

Ely, James W., Jr. The Chief Justiceship of Melville W. Fuller, 1888–1910. Columbia: University of South Carolina Press, 1995.

R. VolneyRiser

See alsoInterstate Commerce Commission ; Public Interest Law .

Cite this article
Pick a style below, and copy the text for your bibliography.

  • MLA
  • Chicago
  • APA

"Granger Cases." Dictionary of American History. . 15 Jul. 2018 <>.

"Granger Cases." Dictionary of American History. . (July 15, 2018).

"Granger Cases." Dictionary of American History. . Retrieved July 15, 2018 from

Learn more about citation styles

Citation styles gives you the ability to cite reference entries and articles according to common styles from the Modern Language Association (MLA), The Chicago Manual of Style, and the American Psychological Association (APA).

Within the “Cite this article” tool, pick a style to see how all available information looks when formatted according to that style. Then, copy and paste the text into your bibliography or works cited list.

Because each style has its own formatting nuances that evolve over time and not all information is available for every reference entry or article, cannot guarantee each citation it generates. Therefore, it’s best to use citations as a starting point before checking the style against your school or publication’s requirements and the most-recent information available at these sites:

Modern Language Association

The Chicago Manual of Style

American Psychological Association

  • Most online reference entries and articles do not have page numbers. Therefore, that information is unavailable for most content. However, the date of retrieval is often important. Refer to each style’s convention regarding the best way to format page numbers and retrieval dates.
  • In addition to the MLA, Chicago, and APA styles, your school, university, publication, or institution may have its own requirements for citations. Therefore, be sure to refer to those guidelines when editing your bibliography or works cited list.