New York Central & Hudson River R. Co. v. United States
212 U.S. 500 (1909)

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U.S. Supreme Court

New York Central & Hudson River R. Co. v. United States, 212 U.S. 500 (1909)

New York Central & Hudson River

Railroad Company v. United States (No. 2)

No. 69

Argued December 14, 15, 16, 1908

Decided February 23, 1909

212 U.S. 500

Syllabus

New York Central R. Co. v. United States, ante, p. 212 U. S. 481, followed as to constitutionality of the Elkins Act of February 19, 1903, c. 708, 32 Stat. 847, and as to when offense of giving rebates in violation of the Interstate Commerce act are complete.

The Elkins Act applies to rebates paid after it went into effect although paid in pursuance of an agreement, and on shipments, made prior to that date, the agreement being illegal when made.

An indictment which definitely sets forth the elements of the offense of which it was intended to charge the accused is sufficient, and in this Court only substantial defects in the indictment are available to reverse a judgment of conviction. Connors v. United States, 158 U. S. 408.

The facts are stated in the opinion.

Primary Holding
A corporation can commit a crime, although not all crimes can be committed by a corporation because of its specific character.
Facts
New York Central and its assistant manager were alleged to have provided rebates to certain companies who were using its trains to transport sugar from New York to Detroit. On appeal, New York Central argued that the Elkins Act was unconstitutional and that a corporation cannot commit a crime. The Act imputed liability to a corporate common carrier for misdemeanors that were committed by officers or agents. More generally, it arranged for the attribution of acts or omissions by officers or agents of the corporation to the corporation.

Opinions

Majority

  • William Rufus Day (Author)
  • Melville Weston Fuller
  • John Marshall Harlan
  • David Josiah Brewer
  • Edward Douglass White
  • Rufus Wheeler Peckham
  • Joseph McKenna
  • Oliver Wendell Holmes, Jr.
  • William Henry Moody

There is no rational argument for why corporations should not be held responsible for crimes that consist of violating a specific federal statute. It is logical to attribute the actions and intentions of their agents to corporations, since the agents are acting under corporate authority. The government might have difficulty enforcing these laws if it could prosecute only individuals for violations of them, since corporations are the true beneficiaries of the violations.

Case Commentary

Corporations generally are liable for strict liability crimes and those in which the legislature appeared to impose liability on corporations, but they are not always liable when the intent of the legislature is unclear.

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