Market Street Railway v. Railroad Commission
United States Supreme Court
324 U.S. 548 (1945)
Relevant factsFree
The Railroad Commission (defendant) ordered Market Street (plaintiff) to reduce its fare, relying on 1943 operating-revenue figures from the company's own monthly filed reports (showing a 20 percent revenue increase) to extrapolate full-year revenue projections, but the commission never formally entered those reports into the administrative record. Market Street sued, arguing the commission's reliance on out-of-record evidence violated its due process rights.
IssueFree
Whether the order of an administrative agency will be overturned based on the agency's use of evidence outside the record if the use did not prejudice the party making the procedural due process claim.
Related cases
International Shoe Co. v. Washington326 U.S. 310 (1945)Ashbacker Radio Corp. v. Federal Communications Commission326 U.S. 327 (1945)National Labor Relations Board v. Hearst322 U.S. 111 (1944)Charles of the Ritz Distributors Corp. v. Federal Trade Commission143 F.2d 676 (1944)Chenery Corp. v. SEC154 F.2d 6 (1946)