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Erb v. Morasch

Supreme Court of the United States
20 S. Ct. 819, 177 U.S. 584, 1900 U.S. LEXIS 1827 (1900)
ELI5:

Rule of Law:

A municipal ordinance that imposes a speed limit on conventional railroad companies but exempts a street railway company does not violate the Equal Protection Clause of the Fourteenth Amendment, provided there is a reasonable basis for the classification.


Facts:

  • In September 1888, the city council of Kansas City passed an ordinance regulating the speed of railroad trains within city limits.
  • Section 2 of the ordinance made it unlawful for any railroad engine or train to run at a speed greater than six miles per hour.
  • Section 8 of the ordinance explicitly exempted the Interstate Rapid Transit Railway Company from this speed limit.
  • The Interstate Rapid Transit Railway was a street railroad connecting Kansas City, Missouri, and Kansas City, Kansas.
  • At the time the ordinance was passed, the Interstate Rapid Transit Railway used steam-powered 'dummy engines', and at the time of the relevant accident, it was powered by electricity.
  • The railroad operated by the receiver, Erb, was a conventional, non-street railroad.
  • An accident occurred involving one of Erb's trains, leading to a lawsuit by Morasch.

Procedural Posture:

  • Morasch sued Erb, the receiver of a railroad company, in a Kansas state trial court to recover for injuries sustained in a train accident.
  • The trial court entered a judgment in favor of Morasch.
  • Erb, as the receiver, appealed the decision to the Supreme Court of Kansas.
  • The Supreme Court of Kansas affirmed the judgment of the trial court, upholding the validity of the city ordinance.
  • Erb then brought the case to the Supreme Court of the United States on a writ of error.

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Issue:

Does a city ordinance that imposes a six-mile-per-hour speed limit on conventional railroad trains, while exempting a specific street railway company, violate the Equal Protection Clause of the Fourteenth Amendment?


Opinions:

Majority - Mr. Justice Brewer

No, the city ordinance does not violate the Equal Protection Clause of the Fourteenth Amendment. A legislative classification is permissible if it is not purely arbitrary and is based on a reasonable distinction. There are substantial differences between a conventional railroad and a street railway, such as the type of track, location within the city, fencing, and motive power, which justify different regulations. The court presumes the validity of municipal legislation and will not substitute its judgment for that of the city council regarding the relative dangers of the two types of railways. As long as a difference exists between the classified entities, it is within the legislative power to apply separate regulations.



Analysis:

This decision solidifies the application of rational basis review to equal protection challenges against municipal safety regulations. It establishes a strong presumption of validity for legislative classifications, giving broad deference to lawmakers. The Court clarifies that for a classification to be upheld, it does not need to be perfect or the most logical one possible; it only needs to rest on some reasonable difference between the groups being treated differently. This case significantly limits the ability to challenge such economic and safety regulations on equal protection grounds, as courts will not second-guess legislative judgments about the necessity or wisdom of a particular classification.

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