{"id":482,"date":"2019-03-01T09:55:48","date_gmt":"2019-03-01T09:55:48","guid":{"rendered":""},"modified":"2021-06-10T15:02:40","modified_gmt":"2021-06-10T15:02:40","slug":"united-states-v-florida-east-coast-7854","status":"publish","type":"post","link":"https:\/\/www.lawteacher.net\/free-law-essays\/administrative-law\/united-states-v-florida-east-coast-7854.php","title":{"rendered":"United States v Florida East Coast Railway Company"},"content":{"rendered":"

Abstract:<\/h3>\n

The Interstate Commerce Commission (ICC) was having a dispute regarding railroad companies borrowing one another\u2019s freight cars rather than constructing new ones consistently leading to a shortage in the United States v. Florida East Coast Railway Company. The ICC established a rule requiring a fee for borrowing each other\u2019s freight cars in an effort to encourage railroads to construct new ones. The East Coast Railway motioned to overturn the rule demanding a formal rulemaking as stated in APA \u00a7556-557 rather than an informal rulemaking defined in APA \u00a7553.\u00a0<\/p>\n

INTRODUCTION<\/h2>\n

The United States v. Florida East Coast Railway Company is an underrated case despite how well known it is. The case\u2019s notoriety is a result of its \u201cblack letter rule\u201d in regard to the rule making procedures. There are several scholars and professionals who are not appreciative of the case for its revealing of three significant and key fundamentals of administrative law. The three fundamentals include the difference between rulemaking and adjudication, the relationship of the judicial, executive, and legislative branches of the United States in defining administrative law, and the importance of the original statute and the Administrative Procedure Act (APA) in shaping the contents of administrative law. To conclude the opinion of Justice Rehnquist\u2019s Court is compelling illustration of the importance and inconsistency of statutory interpretations.<\/p>\n

CASE BACKGROUND<\/h2>\n

In the year 1966, in an effort to give the Interstate Commerce Commission (ICC) the authority to resolve the national freight car shortage of railroads, the United States Congress amended the Interstate Commerce Act (7). The specific subsection that Congress amended was \u00a71(14)(a) which states \u201cenlarge the Commission\u2019s authority to prescribe per diem charges for the use by one railroad of freight cars owned by another.\u201d(8) Following the revised Interstate Commerce Act, the ICC gave a one year grace period prior to enforcing their newly obtained authority that Congress provided them. As of December 1967, railroads were required to report the demand for freight cars to the ICC, as well as the amount of freight cars over a one-year period starting in January of 1968 (9). This raised concerns from the railroads, and as a result of the ICC officials hosted an informal meeting for twenty railroad representatives (10).<\/p>\n

The ICC delivered a report that proposed a regulation requiring railroads that use freight cars from other railroads to pay \u201c\u2018incentive\u2019 per diem charges\u201d as of December 1969 (18). The ICC requested responses to the regulation proposal as well as informed railroads that an explanation for the need of a hearing is requested. The ICC modified multiple aspects of the December 1969 report finalizing in April of 1970, denying several railroads request for a hearing.<\/p>\n

RULEMAKING AND ADJUDICATION<\/h2>\n

The court had contemplated the type of hearing that is required prior to the ICC could enforce per diem rates in the Florida East Coast Railway case (23). The case demonstrates that it is the nature of the hearing enforced by the constitution or a statute is determined by the nature of the agency action.<\/p>\n

\n

\u201cThe term \u2018hearing\u2019 in its legal context undoubtedly has a host of meanings. Its meaning undoubtedly will vary, depending on whether it is used in the context of a rulemaking-type proceeding or in the context of a proceeding devoted to the adjudication of particular disputed facts.\u201d (24)<\/p>\n<\/blockquote>\n

The most significant aspect of administrative law is that individual hearings are not required by Constitutional due process when the government is involved in general resolutions (27). Actions that are supportive and mandatory for determining individual, adjudicative matters are not required when the dispute in question by the agency is categorized as legislative that is involving broad policy decision. Protester claimed the ICC\u2019s governing procedure in Florida East Coast Railway more exclusive in regard to its financial presence. They claimed that it should have caused action to guarantee an appropriate administrative deliberation for the individual impacts (34).<\/p>\n

The fundamental aspect that agencies make two separate categories of decisions is established by Florida East Coast Railway. The case also proves that it depends on the characterization of the decision to make an appropriate procedure for a certain agency decision making. Rulemaking and adjudication is distinguished so well that it illustrates the nature of the hearing that congress ordered as well as the context for assessing the sufficiency of a hearing.\u00a0<\/p>\n

STATUTE AND APA IN ADMINISTRATIVE LAW<\/h2>\n

Florida East Coast Railway is an excellent example of how administrative law content is interpreted by the specific original act in question, as well as the APA requirements. Regardless if the regulation is clear, it could be extremely significant in legal cases. After concluding that the Interstate Commerce Act did not cause the requirements of the APA for a formal hearing the Court had take into account the components of administrative law (35) stating \u201ceven though the Commission was not required to comply with \u00a7 556 and 557 of that Act, it was required to accord the \u2018hearing\u2019 specified in \u00a7 1(14) (a) of the Interstate Commerce Act. Though the District Court did not pass on this contention, it is so closely related to the claim based on the APA that we proceed to decide it now.\u201d\u00a0<\/p>\n

The court found that the original action did not demand hearing requirements that were not previously in place by the APA \u00a7 553 (37). Subsequently the court found that the actions performed by the ICC in the issue regarding rulemaking did not interfere with the original act or the APA (38). However, in other cases the APA requirements maybe supplemented by procedural requirements established by the original act (39).\u00a0<\/p>\n

THE THREE BRANCHES OF GOVERNMENT RELATIONSHIP<\/h2>\n

The third aspect of administrative law that the Florida East Coast Railway demonstrated in regard to defining the law is the importance of the relationship between the judicial, legislative, and executive branches of government<\/a>. Florida East Coast Railway allows for two perspectives to consider for this aspect of administrative law. The perspective of the judiciary branch having the authority to interpret what the law is. The second, Congress having the ability to effect law separate from legislation.\u00a0<\/p>\n

In the Florida East Coast Railway case the issue in question is what procedures of the ICC\u2019s promulgation of regulations established incentive per diem rates. The ICC\u2019s understanding of the procedural requirements was that railroads were required to present evidence regarding the necessity for as well as the impact of incentive per diem rates at an oral hearing. The ICC took this position at the congressional hearing evaluating the per diem rates and agency actions that define them (40). In conjunction with the 1966 statutory delegation of rulemaking authority, Congress had not amended the requirement that the Interstate Commerce Act allows an agency action \u201cafter hearing\u201d or provide a deadline for action if the agency failed to act by a certain date (43). In the end the congressional subcommittee was lawful in their attempt to change the ICC\u2019s interpretation of the law due to the Court being the final arbiter of limitations of congressional authority over lawmaking as well as the interpretation of statutes<\/p>\n

The Florida East Coast Railway case demonstrates the control Courts have when defining the content of the law with the use of interpretation. Originally, Justice Douglas advised deference to ICC\u2019s belief that an oral hearing was required by the Interstate Commerce Act (54). Due to the ICC\u2019s position that an oral hearing is required because of the agency\u2019s understanding of the APA requirements instead of the Interstate Commerce Act the court concluded that the ICC was not owed deference. Since the ICC did not have expertise nor did they assign lawmaking authority of the APA\u2019s requirements interpretation the majority did not defer to the ICC understanding (55). After the majority was capable of resolving the APA formal hearing action conflict in Florida East Coast Railway without deference to the ICC, the nature of the required hearing of the Interstate Commerce Act \u00a7 1(14)(a) still needed to be decided by the majority (57).\u00a0<\/p>\n

Justice Rehnquist viewed that the 1966 Congress\u2019 amendment of Interstate Commerce Act \u00a7 1(14)(a) to sanction imposition of incentive rates, despite not amending the language in the beginning of \u00a7 1(14)(a) (59). Justice Rehnquist utilized this interpretive strategy to claim the 1966 Congress legislation intended the necessary hearing to be appropriate for the promulgation of rulemaking legislation with an eventual effect on rulemaking procedures as defined by the APA 60.\u00a0<\/p>\n

Justice Rehnquist\u2019s law interpretation was reinforced by two vital perspectives. The first being at the time the majority might have overlooked the understanding of the statutory term \u201chearing\u201d. His interpretation was also supported by the Courts view of the 1966 Congress would have determined that the statutory term \u201chearing\u201d to express procedural requirements of rulemaking for the APA (61).\u00a0<\/p>\n

CONCLUSION<\/h2>\n

The decision of Florida East Coast Railway case demonstrates that courts are the ultimate mediator in interpreting administrative law. The courts also have wide spread of strategies for interpreting what a law means. The Florida East Coast Railway case is famous in administrative law for the rule of causing the formal rulemaking process of the APA. Due to the simplicity of the rule in the case in limiting the function of formal rulemaking, significant insight of administrative law that is offered in the case. The Florida East Coast Railway case teaches lessons about basic structure regarding administrative law in the United States.<\/p>\n

References<\/h2>\n

United States v. Florida East Coast Ry. Co., 410 U.S. 224 (1973). (n.d.). Retrieved February 22, 2018, from<\/p>\n

United States v. Florida East Coast Ry. Co., 410 U.S. 224 (1973)<\/p>\n

24 W. S., III. (1998). Briefing: Carl Grays article on Time Management http:\/\/www.bmj.com\/cgi\/content\/full\/316\/7137\/S2-7137 seemed to go \u2026\u00a0Administrative Law Review,<\/em>\u00a0316<\/em>(7149). doi:10.1136\/bmj.316.7149.3a<\/p>\n","protected":false},"excerpt":{"rendered":"

Case Summary of United States v Florida East Coast Railway Company. The decision demonstrates that courts are the ultimate mediator in interpreting administrative law.<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[37],"tags":[84],"class_list":["post-482","post","type-post","status-publish","format-standard","hentry","category-free-law-essaysadministrative-law","tag-us-law"],"yoast_head":"\nUnited States v Florida East Coast Railway Company | LawTeacher.net<\/title>\n<meta name=\"description\" content=\"Case Summary of United States v Florida East Coast Railway Company. 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