Opinion · Supreme Court of the United States
Atchison, Topeka & Santa Fe Railway Co v. Wells
265 U.S. 101
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 1924-05-12
- Topic
- general
How later courts describe this case
- jurisdiction “interfered unreasonably with interstate commerce”
Citator
UpLaw has not yet analyzed Atchison, Topeka & Santa Fe Railway Co v. Wells. The absence of a flag is not a finding that it is good law.
- Cited by
- 97 opinions
Headnotes
- Civil Procedure — Attachment and Garnishment — Interstate Commerce A railroad's rolling stock and traffic balances owing to it are not exempt from seizure by attachment or garnishment merely because the rolling stock is used, and the balances are derived, in interstate commerce. 265 U.S. at 103
- Constitutional Law — Commerce Clause A state statute, as construed and applied, that permits a citizen and resident of another state to prosecute in that state a cause of action arising elsewhere against a railroad corporation of another state engaged in interstate commerce—which neither owns nor operates a railroad in the forum state nor has consented to be sued there—is invalid because such a suit necessarily and unreasonably burdens interstate commerce. 265 U.S. at 103 (citing Davis v. Farmers Co-operative Co., 262 U.S. 312)
- Civil Procedure — Garnishment — Due Process Garnishment proceedings that seize a foreign railroad corporation's rolling stock and traffic credits for the purpose of compelling it to submit to the jurisdiction of a state court in a suit on a cause of action arising elsewhere unreasonably interfere with interstate commerce, and the judgments entered thereon by constructive service are void. 265 U.S. at 103
- Civil Procedure — Collateral Attack on Void Judgments A foreign corporation against which void judgments were entered may seek relief from their enforcement by an injunction in a federal court without first asserting its rights in the courts of the state that rendered them. 265 U.S. at 103
- Civil Procedure — Jurisdiction — Garnishee's Conduct A foreign corporation's right not to be subjected to suit in a state where it has neither consented to be sued nor conducted railroad operations cannot be affected by any act or omission of a garnishee; the invalidity of the garnishment depends on the unreasonable interference with interstate commerce, not on the garnishee's conduct. 265 U.S. at 103
ATCHISON RY. CO.v. WELLS,265 U.S. 101(1924)
44 S.Ct. 469
ATCHISON, TOPEKA SANTA FE RAILWAY COMPANYv. WELLS ET AL.
CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE FIFTH CIRCUIT.
No. 232.
Argued April 23, 1924.
Decided May 12, 1924.
CERTIORARI to a decree of the Circuit Court of Appeals
affirming a decree of the District Court, which dismissed a bill
to enjoin the enforcement of judgments.
The rolling stock held by the garnishee was then being used in interstate commerce and the amount due on traffic balances arose out of transactions in such commerce. These facts did not render the property immune from seizure by attachment or garnishment.Davisv.Cleveland, Cincinnati, Chicago St. Louis Ry. Co.,217 U.S. 157. But the writ of garnishment is void because of the purpose for which it was invoked. The Santa Fe is a Kansas corporation. It had not been admitted to Texas as a foreign corporation. It had not consented to be sued there. It did not own or operate any line of railroad within the State; and had no agent there. The Texas statutes concerning garnishment were construed and applied in the Wells suit so as to permit a citizen and resident of another State to prosecute in Texas a cause of action which arose elsewhere against a railroad corporation of another State, which is engaged in interstate commerce, which neither owns nor operates a railroad in Texas, and which has not consented to be sued there. For the reasons stated inDavisv.Farmers Co-operative Co.,262 U.S. 312(decided since the entry of the judgment here under review) such a suit necessarily and unreasonably burdens interstate commerce; and the statute as construed and applied is invalid.
Relief against the void judgments entered was properly sought by the Santa Fe in the federal court.Simonv.Southern Ry.Co.,236 U.S. 115;Wells Fargo Co. v.Taylor,254 U.S. 175. SeeEssanay Film Co. v.Kane,258 U.S. 358,360. The garnishment was void because seizure of the rolling stock and credits for the purpose of compelling the Santa Fe to submit to the jurisdiction of the court in the Wells suit interfered unreasonably with interstate commerce. The Santa Fe was not obliged to assert its rights in the courts of Texas. CompareFirestonePage 104Tire Rubber Co. v.Marlboro Cotton Mills, 282 F. 811, 814. Nor could its right not to be sued there be affected by anything which the garnishee did or omitted to do. Moreover, the garnishee's objection to the jurisdiction (on grounds later upheld by this Court in theFarmers Co-operative Co. Case) had been overruled by the state court. We have no occasion, therefore, to consider further the scope or the provisions of the statutes concerning garnishment.Reversed.
- Page 102 SeeAtchison, T. S.F. Ry. Co. v.Weeks, 254 F. 513. ↩