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Constitutional Law Keyed to Choper
Bibb v. Navajo Freight Lines
Citation:
359 U.S. 520 (1959)Facts
In 1957, Illinois enacted a statute requiring trucks and trailers operating on its highways to be equipped with contoured mudguards that followed the curvature of the wheel. This requirement conflicted with Arkansas regulations mandating conventional straight mudflaps. The evidence showed that changing between the two types of mudguards required 2-4 hours of labor and welding, which was particularly problematic for carriers transporting explosives. The Illinois requirement also disrupted “interline” operations, where trailers are transferred between carriers without unloading cargo, which was crucial for perishable goods and hazardous materials. The District Court found that the contour mudguards offered no safety advantages over conventional mudflaps and actually created new safety hazards by causing brake overheating and being susceptible to damage. The cost to install contour mudguards ranged from $4,500 to $45,840 for the plaintiff carriers, who operated extensively in interstate commerce but traveled only a small percentage of their total mileage in Illinois.
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