Louisiana Ry. & Nav. Co. v. Behrman - 235 U.S. 164 (1914)
U.S. Supreme Court
Louisiana Ry. & Nav. Co. v. Behrman, 235 U.S. 164 (1914)
Louisiana Railway & Navigation Company v. Behrman
Argued November 4, 5, 1914
Decided November 30, 1914
235 U.S. 164
While the jurisdiction of this Court under § 237, Judicial Code, may not attach where the state court gave no effect to the state enactment claimed to have impaired the obligation of a contract, where the state does give effect to later legislation which does impair the obligation of a contract, if one exists, this Court has jurisdiction to, and must, determine for itself whether there is an existing contract, even though the state court may have put its decision upon the ground
that the contract was not made, was invalid, or had become inoperative.
In determining whether effect has been given to later legislation, this Court is not limited to mere consideration of the language of the opinion of the state court.
This Court has jurisdiction under § 237, Judicial Code, to determine whether there is a contractual obligation which plaintiff in error is entitled to enforce without its being impaired by the operation of subsequent legislation enacted by or under the authority of the state.
While courts should give them a fair and reasonable interpretation, public grants are not to be extended by implication beyond their clear intent.
As the ordinance on which the contract claimed to have been impaired was based was intended to confer rights exclusively with reference to an existing plan of construction, and as that plan proved abortive because of legal obstacles to its fulfillment, no rights were conferred thereby, and a later ordinance on the same subject cannot be deemed invalid under the impairment of obligation clause of the federal Constitution.
An ordinance of the City of New Orleans regarding construction of the Belt Railroad held not unconstitutional because it impaired the obligation of a contract based on a former ordinance, as such contract was subject to a suspensive condition, and the event in which the obligation was to arise had not happened.
127 La. 775 affirmed.
The facts, which involve the jurisdiction of this Court under § 237, Judicial Code, and also the constitutionality under the impairment of obligation provision of the federal Constitution of an ordinance of the City of New Orleans relating to the construction and operation of a belt railroad within the city, are stated in the opinion.