Rice v. Santa Fe Elevator Corp.

Rice v. Santa Fe Elevator Corp.
Supreme Court of the United States
Argued February 13–14, 1947 Decided May 5, 1947
Full case name	Rice v. Santa Fe Elevator Corp.
Citations	331 U.S. 218 (more) 67 S. Ct. 1146; 91 L. Ed. 1447; 1947 U.S. LEXIS 2938
Holding
When Congress legislates in a field which the States have traditionally occupied the Court starts with the assumption that the police powers of the States were not superseded by the federal law unless that was the clear and manifest purpose of Congress.
Court membership
Case opinions
Majority	Douglas, joined by Vinson, Black, Reed, Murphy, Jackson, Burton
Dissent	Frankfurter, joined by Rutledge
Laws applied
United States Warehouse Act, Illinois Public Utilities Act, Illinois Grain Warehouse Act

Rice v. Santa Fe Elevator Corp. 331 U.S. 218 (1947), is a case dealing with "field preemption": the United States Supreme Court held that when a federal law regulates a field traditionally occupied by the states, the police powers of the States in that area of law are not necessarily preempted; Congress must also manifest a clear and manifest purpose to do so.

Illinois sued several grain warehousemen for violating Illinois grain warehousing regulations. The warehouseman sued in federal court, arguing that the state regulations were preempted by a related federal law. The District Court overturned his claim, but the appellate court reversed.

The question turned on how to interpret the intention of Congress. Respondents argued that the law should be construed to mean that Illinois may not regulate subjects in any related area, even though the scope of federal regulation is not as broad as the regulatory scheme of the state and even though there is or may be no necessary conflict between what the state agency and the federal agency do. Petitioners (Illinois') argue that since the area taken over by the federal government is limited, the rest may be occupied by the States; that State regulation should not give way unless there is a precise coincidence of regulation or an irreconcilable conflict between the two.

The Illinois Commerce Commission regulated grain warehouses, pursuant to the Illinois Public Utilities Act, Ill.Rev. Stats.1945, ch. 111 2/3, the Illinois Grain Warehouse Act, Ill.Rev. Stats.1945, ch. 114, §§ 189 et seq., and Art. XIII of the Illinois Constitution.

The original U.S. Warehouse Act, as enacted in 1916 (39 Stat. 486), explicitly made federal regulation in this field subservient to state regulation.

In 1931, Congress amended the act. 46 Stat. 1463.

In this case, the Court determined that Congress's intent, when it amended § 6 and § 29 of the Act, was to eliminate the dual state and federal regulation of any warehouse that chose to obtain a federal license:

Conclusion: "The test, therefore, is whether the matter on which the State assets the right to act is in any way regulated by the Federal Act. If it is, the federal scheme prevails though it is a more modest, less pervasive regulatory plan than that of the State. By that test each of the nine matters we have listed is beyond the reach of the Illinois Commission since on each one Congress has declared its policy in the Warehouse Act. The provisions of Illinois law on those subjects must therefore give way by virtue of the Supremacy Clause. U.S.Const., Art. VI, Cl. 2."

By Mr. Justice FRANKFURTER, with whom Mr. Justice RUTLEDGE concurs ...