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Regulatory Law Keyed to Shapiro, 4th Ed.
Department of Transportation v. Association of American Railroads
Citation:
575 U.S. 43 (2015)Facts
In 1970, Congress created the National Railroad Passenger Corporation (Amtrak) to preserve passenger rail services in the United States. Amtrak relies on track systems owned by freight railroads for most of its operations. In 2008, Congress passed the Passenger Rail Investment and Improvement Act (PRIIA), which authorized Amtrak and the Federal Railroad Administration to jointly develop metrics and standards for measuring the performance of intercity passenger train operations. These metrics and standards address matters including on-time performance and train delays caused by host railroads. The Association of American Railroads, representing freight railroad companies, challenged this provision, arguing that it unconstitutionally delegated regulatory authority to Amtrak, which it considered a private entity. The Association claimed that this delegation violated both the nondelegation doctrine and the Due Process Clause because Amtrak, as a supposedly private entity, was regulating its own industry while pursuing its own economic interests.
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