New York Central & Hudson River Railroad Co. v. United States
United States Supreme Court
212 U.S. 481 (1909)
Relevant factsFree
New York Central & Hudson River Railroad Company (defendant), a common carrier bound by the federal Elkins Act's prohibition on charging shipping rates below the posted rate, was convicted, along with one of its employees, of paying rebates to shippers that unlawfully lowered their effective shipping rates. The railroad appealed, arguing the Act was unconstitutional insofar as it allowed Congress to impute criminal liability to a corporation and subject it to criminal prosecution for its agents' acts.
IssueFree
Whether a corporation may be held criminally culpable for acts committed by its employee agents within the scope of their employment and for the corporation's benefit.