Railroad Rate Regulation, With Special Reference to the Powers of the Interstate Commerce Commission Under the Acts to Regulate Commerce

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382, 29 Sup.
R. R. Commission, 156 Fed. 823. Ct. 192.
'8 Missouri R. & R. T. Co. v. Love, " Cedar Rapids Water Co. v.
177 Fed. 493. Cedar Rapids, 118 Iowa, 234, 91 "Louisville & N. Ry. Co. v. N.W. 1081.
Brown, 123 Fed. 946. ^^ State ex rel. v. Seaboard A. L.
™ Willcox V. Consolidated Gas Co., R. R. Co., 48 Fla. 129, 37 So. 314.
[266] Rate of Return [ § 318 speaking proof that the net earnings which will be left by the proposed reduction will leave an absurdly low per- centage, as in one recent
...case *^ two and one-third per cent, is enough to condemn the legislative rate. In one of the latest federal cases *^ it is said succinctly that the authori- ties practically establish a six per cent minimum. This is based upon the doctrine in Cotting v. Kansas City Stock Yards Company; *^ the court said in effect that legis- lation cutting the return of the company below six per cent was unconstitutional. Confined by the courts to this extent, regulation by commissions should have no terror to the investor.

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