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Published online by Cambridge University Press: 15 April 2016
Revisiting the origins of the Interstate Commerce Commission (ICC) created in 1887 and offering a fresh interpretation that the commission was conceived and operated as a highly court-like agency, this paper argues that its emergence triggered the judicialization of the U.S. administrative state. It has been argued that the blueprint of the ICC took after existing railroad commissions. Its proponents in Congress, however, redesigned it with judicial courts as a model after facing criticisms based on the common-law principle of the supremacy of law allowing adjudication only to judicial courts. In accordance with such an institutional scheme, both the president and judiciary promoted the commission's judicialization by appointing lawyers as its members and reviewing its decisions. By the early twentieth century, the ICC was a prototypical agency whose court-like features permeated the administrative state. This paper thus offers a corrective to the literature on the U.S. administrative state building that has come to trivialize the role of the rise of the ICC. It was, instead, a critical juncture in the emergence of the modern administrative state in which being “quasi-judicial” was the norm rather than the exception for an administrative agency.
The author thanks Sheila A. Hones, Sayuri Guthrie Shimizu, Kensuke Takayasu, the Journal's anonymous reviewers, and participants in the 2011 American Political Science Association Annual Meeting panel on “Law and the Rights Revolution” for very helpful comments. The hospitality of the faculty and staff at University of Virginia School of Law, at which bulk of preparation for this work was made, is warmly acknowledged. Research for this paper was supported by the JSPS Grants-in-Aid for Scientific Research.
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24 John F. Kennedy, “Special Message to the Congress on the Regulatory Agencies,” Apr. 13, 1961, John T. Woolley and Gerhard Peters, The American Presidency Project, http://www.presidency.ucsb.edu/ws/?pid=8058 (accessed Apr. 22, 2013).
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31 Congressional Record, 48th Congress, 2nd sess. (Dec. 18, 1884), 328–30. A newspaper noted that the Cullom bill's ICC was “really a court to try certain specified railroad offences.” Chicago Tribune, Feb. 4, 1885.
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33 The term “Reaganite” was used in the 1880s to refer to the supporters of the Reagan bill. See, for instance, The Statist, Jan. 22, 1887, 92.
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39 59 U.S. 272 (1856). The Supreme Court later admitted agency adjudication of private rights in Crowell v. Benson, 285 U.S. 22 (1932).
40 The latter principle would later play a central role in the battles over administrative procedures owing much to Albert V. Dicey's seminal work, Lectures Introductory to the Study of the Law of the Constitution (London: Macmillan, 1885).
41 In the Forty-Ninth Congress, however, Sen. John Morgan (D-AL) attacked the Cullom bill stating that the ICC would take away the power “for the settlement of the private rights” from the judiciary. Congressional Record, 49th Congress, 2nd sess. (Jan. 6, 1887), 399.
42 Congressional Record, 48th Congress, 2nd sess. (Jan. 7, 1885), 517.
43 Congressional Record, 48th Congress, 2nd sess. (Jan. 17, 1885), 808.
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61 Also, in Section Eighteen, the commissioners' salaries were made to be “payable in the same manner as the salaries of judges of the courts of the United States.”
62 Congressional Record, 49th Congress, 1st sess. (May 10, 1886), 4307.
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70 Contrary to James's view, Reagan's acceptance of the ICC may not have meant the jettisoning of his “core agrarian conviction” against regulation by agencies. James, Presidents, Parties, and the State, 102–3. In the Forty-Eighth Congress, some Reaganites had expressed their readiness to support a commission bill with provisions specifying the practices to be banned. Congressional Record, 48th Congress, 2nd sess. (Dec. 4, 1884), 64, (Jan. 20, 1885), 858.
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