Document Type



The Judicial Interpretation of Public Utility Franchises, 39 Yale Law Journal 957 (1930)


The United States Supreme Court has recently added one more
decision to the long list of cases on the contractual aspects of
public utility franchises. The specific question before the court
was the review of a permanent injunction granted by a federal
district court of three judges to restrain the railroad commission
of California from enforcing against the Los Angeles Railway
Corporation the provisions for rates of fare embodied in a series
of franchises under which the company operated. The franchises
had been granted successively from 1886 to 1928 and had provided
generally that the rate of fare should not exceed five cents,
although in some of the later ordinances it was also stated that
an increase might be permitted by proper showing before "a
competent authority having jurisdiction over rates of fare..."

Date of Authorship for this Version



public utility franchise, railroad, court