Railway Express Agency, Inc. v. New York Case Brief
Summary of Railway Express Agency, Inc. v. New York (1949)
Relevant Facts: NY passes a law preventing businesses from advertising on their vehicles. PL runs a nationwide courier business, which advertises on its trucks (mostly unconnected with its business). Convicted in the magistrate's court and fined, sustained in Court of Special Sessions and Court of Appeals. This Court
Issue: Under constitutional law, does a NY ban on general advertising on business vehicles discriminate businesses from operating in the livelihood expected under the 5th and 14th amendments?
Holding: No. The ends justify the means, as preventing distractions to drivers in the city was served by the purpose of this law.
Court's Rationale/Reasoning: Means of the law was to prevent distractions to drivers. The law passed was meant to ban only unrelated advertising on businesses' vehicles, not all advertising, so it is not discriminatory. PL contends the law discriminates not only on the basis of advertisements on trucks, but also to trucks in general. The Court finds this unconvincing.
The Court is unwilling to question the municipality's judgment in passing such a law; it would be stepping on their toes in effect, to tell them how to run their government. The Court cannot see exactly how effective such a law would be as an outside party when it is the municipality which knows its city the best.
If the city describes the law as one which prevents distractions to other drivers in order to avoid accidents, this Court trusts their judgment. It is by such practical considerations based on experience rather than by theoretical inconsistencies that the question of equal protection is to be answered. The fact that the city doesn't deal with billboard ads or building ads is immaterial, as long as the judgment of NYC is legitimate.
Rule: Rational basis scrutiny: ends must justify the means. The classification has relation to the purpose for which it is made and does not contain the kind of discrimination against which the Equal Protection Clause affords protection.
Important Dicta: N/A.
Concurring: (Justice Jackson): Burden rests heavily upon anyone who wants the Court to use the due process clause to strike down laws/ordinances. But using the EPC does not offend the people as much.
Cities, states, and the Federal Gov't must exercise their powers so as not to discriminate between their inhabitants except upon some reasonable differentiation fairly related to the object of regulation. The Framers knew this.
The city's means is not to regulate all advertising, or all ads on vehicles: this is only meant to cease certain ads unrelated to businesses on those businesses' vehicles. There is no problem here; it's not arbitrary. The city could even go so far as to limit the size, shape and coloring if they wished, as long as the ends justified the means.