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Legislation and Regulation Keyed to Manning, 5th Ed.
Rice v. Santa Fe Elevator Corporation
Citation:
331 U.S. 218 (1947)Facts
The Rice partnership, grain owners and dealers, along with the Illinois Commerce Commission, brought action against several grain warehousemen operating under federal licenses issued pursuant to the United States Warehouse Act. The complaint alleged numerous violations of Illinois law, including charging unreasonable rates, discriminating in storage rates, mixing high quality public grain with inferior grain, operating without a state license, and failing to file rate schedules. The warehousemen contended that the 1931 amendments to the United States Warehouse Act made federal regulation exclusive, thereby preempting state authority over federally licensed warehouses. The 1931 amendments had changed the language of the Act from making it subservient to state law to providing that “the power, jurisdiction, and authority” of the Secretary of Agriculture “shall be exclusive with respect to all persons securing a license” under the Act. The legislative history indicated Congress intended to make the federal act “independent of State laws” and place it “on its own bottom.”
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