Vandalia R. Co. v. Public Service Comm'n
Annotate this Case
242 U.S. 255 (1916)
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U.S. Supreme Court
Vandalia R. Co. v. Public Service Comm'n, 242 U.S. 255 (1916)
Vandalia Railroad Company v.
Public Service Commission of Indiana
Submitted November 6, 1916
Decided December 11, 1916
242 U.S. 255
Prior to the Act of March 4, 1915, c. 169, 38 Stat. 1192, and after the Act of February 17, 1911, c. 103, 36 Stat. 913, the state police power extended to the regulation of the character of headlights used on
locomotives employed in interstate commerce. Atlantic Coast Line v. Georgia, 234 U. S. 280.
A judgment which correctly refused injunctive relief against such state regulation may not be attacked on writ of error as a judgment infringing federal rights (Judicial Code, § 237) upon the ground that the same field of regulation has since been occupied by tho federal government under an act of Congress enacted after the judgment was rendered.
The question whether, because of the Act of 1915, supra, or action of the Interstate Commerce Commission thereunder, further enforcement of the order of the state commission here involved would infringe the plaintiff's rights may be raised and determined in another action without prejudice from this one.
An order of a state commission requiring a carrier to equip its locomotives with headlights of a specified minimum candlepower is not objectionable as lacking due process when made on notice and full hearing, and where the law under which the commission acted afforded opportunity for review in the courts, of which the complaining carrier availed itself.
Complaint that such an order is so indefinite and uncertain as to amount to a denial of due process will not be heard where the party complaining failed to take advantage of a legal opportunity to have the order revised through a rehearing before the commission.
182 Ind. 382 affirmed.
The case is stated in the opinion.