United States v. Ludlum Steel Corp.

The Interstate Commerce Commission (ICC) had statutory authority under the Esch Car Service Act to establish railroad car-service rules after a hearing, whether on complaint or on its own initiative, but that statute did not require the resulting rules to be made "on the record." Ludlum Steel Corp. and other shippers (plaintiffs) sought judicial review of ICC rules issued through informal rulemaking, arguing the APA required a formal, trial-type hearing before any such rule could be promulgated.