Supreme Court of the United States
The Richmond, Fredericksburg, and Potomac Railroad Company, Plaintiffs in Error v. the Louisa Railroad Company
February 18, 185254 U.S. 71
Summary
The Supreme Court affirmed the Virginia Court of Appeals, holding that the 1848 Virginia act authorizing the Louisa Railroad to extend its line does not impair the contract obligation in the Richmond, Fredericksburg, and Potomac Railroad’s charter and therefore no injunction may be issued. The Court applied a strict construction rule to public grants and left any future dispute over passenger transport to be resolved at law.
Holding
- Whether the 1848 Virginia act authorizing the Louisa Railroad’s extension impairs the contract obligation in the 38th section of the Richmond company's charter.. The act does not impair the contract; the extension may proceed and no injunction is warranted.
- Whether a state may authorize a railroad to cross another railroad’s line without violating the charter contract.. A franchise to build a railroad may be crossed by another railroad, with appropriate compensation; such crossing does not constitute a breach of the charter contract.
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