Houston, East & West Texas Railway Co. v. United States (Shreveport Rate Case) 234 U.S. 342 (1914)
HOUSTON, EAST & WEST TEXAS RAILWAY CO. v. UNITED STATES (Shreveport Rate Case) 234 U.S. 342 (1914)
To relieve a competitive inequality in rail rates, the Interstate Commerce Commission (ICC) ordered the Texas Railroad Commission to raise intrastate rates to equal interstate rates. Shreveport, Louisiana, to east Texas rates, set by the ICC, were higher than west Texas to east Texas rates, fixed by the states, thereby placing interstate commerce at a competitive disadvantage. With only Justices horace lurton and mahlon pitney dissenting, Justice charles evans hughes relied on the interstate commerce act and the commerce clause in upholding the ICC order. Hughes distinguished the minnesota rate cases (1913) as neither involving an attempt at federal regulation nor adversely affecting or burdening interstate commerce. Emphasizing Congress's "complete and paramount" power over interstate commerce, he announced the shreveport doctrine : "Wherever the interstate and intrastate transactions of carriers are so related that the government of the one involves the control of the other, it is Congress and not the state, that is entitled to prescribe the final and dominant rule."