Wabash, St. Louis & Pacific Railway Co. v. Illinois

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Wabash, St. Louis & Pacific Railway Company v. Illinois
Argued April 14–15, 1886
Decided October 25, 1886
Full case nameWabash, St. L. & P. Ry. Co. v. People of State of Illinois
Citations118 U.S. 557 (more)
7 S. Ct. 4; 30 L. Ed. 244
The Court held that Illinois had violated the Commerce Clause by placing a direct burden on interstate commerce. Under the Commerce Clause only Congress had the power to do so and states could only place indirect burdens on commerce.
Court membership
Chief Justice
Morrison Waite
Associate Justices
Samuel F. Miller · Stephen J. Field
Joseph P. Bradley · John M. Harlan
William B. Woods · Stanley Matthews
Horace Gray · Samuel Blatchford
Case opinions
MajorityMiller, joined by Field, Harlan, Woods, Matthews, Blatchford
DissentBradley, joined by Waite, Gray
Laws applied
U.S. Const. amend. XIV
This case overturned a previous ruling or rulings
Munn v. Illinois (1877)

Wabash, St. Louis & Pacific Railway Company v. Illinois, 118 U.S. 557 (1886), also known as the Wabash Case, was a Supreme Court decision that severely limited the rights of states to control or impede interstate commerce. It led to the creation of the Interstate Commerce Commission.

The court[edit]

The majority's opinion was written by Justice Samuel Miller; joining him were associate justices Stephen Field, John Harlan, William Woods, Stanley Matthews, and Samuel Blatchford. Dissenting were Chief Justice Morrison Waite and associate justices Joseph Bradley and Horace Gray.[1]

The case[edit]

The case was argued on April 14, 1886 - April 15, 1886 and was decided on October 25, 1886 by vote of 6 to 3. Associate Justice Miller wrote for the Court with Associate Justices Field, Harlan, Woods, Matthews, and Blatchford concurring; Associate Justices Bradley and Gray, along with Chief Justice Waite, dissented.

In Wabash, "direct" burdens on interstate commerce were not permitted by the Export Tax Clause of the Constitution (Article I, Section 9); however, those "indirect" burdens were permitted under the Commerce Clause. This was a standard enacted in Cooley v. Board of Wardens (1852).

Effects of decision[edit]

  • The Wabash decision led to the creation in 1887 of the first modern regulatory agency, the Interstate Commerce Commission.
  • It clarified the "direct" v. "indirect" test (though this doctrine was abandoned in the 1930s).
  • It was one of the first instances in government assuming responsibility for economic affairs that had previously been delegated to the states.

See also[edit]


  1. ^ Wabash, St. Louis & Pacific Railway Co. v. Illinois, 118 U.S. 557 (1886).

External links[edit]

  • Works related to Wabash, St. Louis & Pacific Railway Co. v. Illinois at Wikisource
  • Text of Wabash, St. Louis & Pacific Railway Company v. Illinois, 118 U.S. 557 (1886) is available from: Findlaw  Justia  Library of Congress 
  • "Wabash Case". InfoPlease Encyclopedia. Retrieved March 1, 2005.
  • Supreme Court cases citing Wabash