Quincy Railways v. Chicago (1897)
The landmark case we explore this month is Quincy Railways v. Chicago (1897), which illustrates the doctrine of incorporation, or the application of Bill of Rights protections to the states through the Fourteenth Amendment. The Supreme Court held that states must honor the Fifth Amendment’s requirement that just compensation be paid to owners when the government takes property. The case opened the door to other claims against states, and broadened the scope of the Bill of Rights’ protections.
In 1897, a dollar could buy a yearly newspaper subscription, or perhaps a night’s stay a nice hotel. Was it “just compensation” for the Chicago, Burlington & Quincy Railroad Company when the city of Chicago widened a street through their land?
The city of Chicago planned to widen Rockwell Street, which required a crossing through land owned by the railroad company. Illinois law said that when the government took property for public use, a jury would decide the amount to be paid to the owner. The jury members heard evidence about the land’s value from both the railroad and the city. They discussed and came to the conclusion that one dollar was just compensation since the city had not actually taken his land, but rather only interfered with his free use of it by putting a street across his right of way. The railroad company asked for a new trial, but the motion was denied and the Supreme Court of Illinois upheld the one-dollar payment.
The U.S. Supreme Court affirmed the Illinois law and found that it amounted to sufficient due process required by the Fourteenth Amendment. The Fourteenth Amendment reads in part, “… nor shall any state deprive any person of life, liberty, or property, without due process of law .” The Court used part of the federal Bill of Rights—the Fifth Amendment and its requirement of just compensation for private property taken for public use—to interpret the constitutionality of a state action. The Supreme Court held that states must honor the Bill of Rights requirement to pay owners just compensation.
Though the railroad company lost, the case would go down in history. The railroad company’s claim prompted the Supreme Court to use the Fourteenth Amendment’s due process requirements to interpret state, not just federal, laws. In Quincy, the Supreme Court said states must provide just compensation when they take land for public use—as provided by the Fifth Amendment.
When the Supreme Court applies a part of the Bill of Rights to a state action, it is said to have “incorporated” that amendment. Incorporation has increased the Supreme Court’s caseload considerably, giving it more power to define rights, and fundamentally changed the meaning of the Bill of Rights, which originally applied only to the federal government. It also made individual citizens more powerful by giving them a way to challenge state actions that they believed violate Bill of Rights protections.
- Why did the Supreme Court uphold the one-dollar judgment to the railroad owner?
- Do you think that the one dollar payment was just compensation?
- Why is Quincy Railways v. Chicago a landmark case?