Western Un. Tel. Co. v. Esteve Bros. & Co., 256 U.S. 566 (1921) (No. 491)
1921
Western Un. Tel. Co. v. Esteve Bros. & Co., 256 U.S. 566 (1921) (No. 491)
Supreme Court of the United States
1921
Case name: Western Un. Tel. Co. v. Esteve Bros. & Co. Opinion filed: 1921-06-01 Docket No.: 491 Citations: • 256 U.S. 566 • 41 S. Ct. 584 • 65 L. Ed. 1094 • 1921 U.S. LEXIS 1589 Case holding summaries: • interpreting the superseded Act to Regulate Commerce • holding state-law challenges to limitation of liability clauses are barred due to the preemptive effect of “the requirement of equality and uniformity of rates laid down in § 3 of the [ICA]” • “Since any deviation from the lawful rate would involve either an undue preference or an unjust discrimination, a rate lawfully established must apply equally to all, whether there is knowledge of it or not.” • all common carriers subject to antidiscrimination principle, but differences exist between railroads and telecommunications carriers as to relationship with ICC • holding state-law challenges to limitation of liability clauses are barred due to the preemptive effect of "the requirement of equality and uniformity of rates laid down in § 3 of the [ICA]" • "Since any deviation from the lawful rate would involve either an undue preference or an unjust discrimination, a rate lawfully established must apply equally to all, whether there is knowledge of it or not." • explaining that an approved tariff governs the utility’s services “not as . . . a matter of contract, . . . but [as] a matter of law”
