210 THE GRANGER MOVEMENT 



estopped from interfering. In the first of these cases Chicago, 

 Burlington, and Quincy Railroad Company v. Iowa, an appeal 

 from the Circuit Court of the United States for the district of 

 Iowa the opinion of the court applied the principle of Munn v. 

 Illinois. It was admitted that the charter was a contract 

 which could not be impaired by a state law; but it was pointed 

 out that the charter in question was obtained under the general 

 incorporation law of Iowa, which reserved to the legislature 

 the right to make rules and regulations. 



In Peik v. Chicago and Northwestern Railway Company and 

 Lawrence v. same, both Wisconsin cases, the special point in- 

 volved was a provision in the charter of the company by which 

 it was specifically authorized " to demand or receive such sum 

 or sums of money for the transportation of persons and prop- 

 erty, and for the storage of property, as it shall deem reason- 

 able." The railroad attorneys maintained that by this express 

 grant the state was estopped from regulating the charges of 

 the company. It was shown, however, that the state constitu- 

 tion, in force when the charter was granted, contained a provision 

 declaring that all acts creating corporations " may be altered 

 or repealed by the legislature at any time after their passage," 1 

 and the court held that this restriction permitted the legisla- 

 ture to place the corporation on the same footing as a natural 

 person. 



The question of interstate commerce was brought up in these 

 cases again, as the Wisconsin law applied to all shipments taken 

 up or set down within the state. The court here went even 

 further than in Munn v. Illinois by declaring that " until Con- 

 gress acts in reference to the relations of this company to inter- 

 state commerce, it is certainly within the power of Wisconsin 

 .to regulate its fares, etc., so far as they are of domestic concern." 

 With regard to the reasonableness of the rates fixed, the court 

 declared as in Munn v. Illinois that it was bound by the limit 

 fixed by the legislature and "if it has been improperly fixed, 

 the legislature, not the courts, must be appealed to for the 

 change." The principles of Munn v. Illinois and Chicago, 



1 See above, p. 179. 



