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Charles River Bridge v. Warren Bridge

United States Supreme Court

36 U.S. 420 (1837)

Relevant factsFree

Massachusetts chartered the Proprietors of the Charles River Bridge (PCRB) (plaintiff) in 1785 to build a toll bridge, later extending the charter to 72 years. In 1828, the legislature chartered the Proprietors of the Warren Bridge (defendant) to build a second, nearby bridge that would become free and state-owned after only six years. PCRB sued to enjoin the Warren Bridge's construction and later for lost profits, arguing its charter implicitly promised no competing bridge would be built. The Massachusetts high court dismissed PCRB's suit, and PCRB sought review from the U.S. Supreme Court, by which time the Warren Bridge had already become free, state-owned property.

IssueFree

Whether a legislative charter authorizing a corporation to build a public improvement, without expressly prohibiting competing projects, implicitly bars the legislature from later authorizing a competing improvement.

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