New York Central & Hudson River Railroad Co. v. United States

212 U.S. 481 (1909)

Quick Summary

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New York Central & Hudson River Railroad Co. (defendant) was prosecuted for providing illegal rebates to shippers, contrary to the Elkins Act. The case centered on whether a corporation could be criminally liable for such actions.

The Supreme Court upheld the conviction, affirming that corporations can be punished for crimes committed by their agents within their employment scope, thereby endorsing the authority of Congress to regulate interstate commerce and enforce equal rights among shippers.

Facts of the Case

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The New York Central & Hudson River Railroad Company (defendant) was indicted for violating the Elkins Act by providing rebates to shippers, specifically the American Sugar Refining Company, which effectively reduced shipping rates below the published tariff rate.

The payments were disguised as rebates and were made after the full tariff rate was initially paid by the shippers. This practice was a clear circumvention of the federal law designed to ensure fair and transparent pricing in interstate commerce.

During the trial, it was established that the rebates were agreed upon to retain the business of shippers who might have otherwise used alternative transportation methods and to help them compete in the market. The company’s traffic managers were authorized to set shipping rates and were fully aware of the legal requirements to file and publish these rates. Despite this, they engaged in an illicit agreement to provide rebates, thus violating federal law.

Procedural Posture and History

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  1. New York Central and its employee were convicted of paying illegal rebates in violation of the Elkins Act.
  2. New York Central appealed, challenging the constitutionality of certain provisions of the Elkins Act.
  3. The case was brought before the Supreme Court of the United States after the Circuit Court’s ruling.

I.R.A.C. Format


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  • Whether a corporation can be held criminally liable for the illegal actions of its agents under the Elkins Act.
  • Whether such provisions in the act are constitutional.

Rule of Law

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The Elkins Act holds corporations responsible for criminal acts committed by their agents while exercising their lawful authority. This statute reflects public policy interests in regulating interstate commerce and preventing favoritism by enforcing equal rights and transparency in shipping rates.

Reasoning and Analysis

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The Court reasoned that corporations, like individuals, can be held criminally liable for their agents’ actions within the scope of their employment, especially when these actions benefit the corporation. The Court rejected the notion that corporations cannot commit crimes, citing modern legal authority which holds corporations accountable for both misfeasance and nonfeasance.

Furthermore, it was emphasized that holding corporations responsible for their agents’ crimes is essential for effective regulation of interstate commerce. The intent and knowledge of an agent acting within their authority are attributed to the corporation, thereby upholding public policy against rebating practices prohibited by the Elkins Act.


Conclusion Icon

The Supreme Court affirmed the judgment of the Circuit Court, holding New York Central criminally liable for rebates paid in violation of the Elkins Act.

Key Takeaways

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  1. Corporations can be held criminally liable for actions taken by their agents within the scope of their employment.
  2. The Elkins Act is constitutional in imposing criminal liability on corporations for rebating practices that violate federal law regulating interstate commerce.
  3. The decision reinforces the notion that corporate entities cannot escape criminal liability simply because they act through agents.

Relevant FAQs of this case

What legal principles establish a corporation's criminal liability for its employees' actions?

Corporate criminal liability arises under the principle of ‘respondeat superior’, where employers are held accountable for employees’ acts committed within the scope of their employment and intended, at least in part, to benefit the corporation.

  • For example: If a restaurant manager, employed by a food chain, deliberately violates health codes to reduce costs and increase profits, the company could be held criminally liable for these intentional violations under ‘respondeat superior’.

What are the implications of the legal doctrine 'vicarious liability' on corporate practices?

Vicarious liability imposes duties on corporations to ensure adherence to laws by their agents, influencing stringent internal compliance programs and corporate governance.

  • For example: A delivery company might implement rigorous training and monitoring systems for its drivers to prevent speeding, understanding that any unlawful act could implicate the company through vicarious liability.

How does the law balance corporate benefits from illegal acts versus the lack of direct knowledge by upper management?

The law attributes an agent’s knowledge and intent to the corporation if actions are taken within the course of employment and are meant to benefit the corporation, irrespective of upper management’s direct knowledge of the specifics of those illegal acts.

  • For example: A salesperson at a car dealership clandestinely rolls back odometers to make used cars more attractive. Even without direct management knowledge, the dealership benefits and may be held criminally liable for fraud since such actions fall within the salesperson’s employment scope.


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