303 U.S. 177, 184–85 n. 2 (1938)
The South Carolina General Assembly enacted Act No. 259 on April 28, 1933.1 This statute prohibits the use on state highways of motor trucks and semi-trailer motor trucks whose width exceeds 90 inches or whose gross weight including load exceeds 20,000 pounds.2 The Act treats semi-trailer motor trucks as single units for purposes of the weight limitation.3
Barnwell Brothers, Inc., along with other truckers and interstate shippers, the Interstate Commerce Commission, and additional intervenors, brought suit in the United States District Court for the Eastern District of South Carolina against state highway department officials.4 They sought to enjoin enforcement of the weight and width provisions on the grounds that the provisions had been superseded by federal law, that they infringed the Due Process Clause, and that they burdened interstate commerce.5
After hearing evidence, the three-judge district court ruled that the provisions had not been superseded by the Federal Motor Carrier Act of 1935 and that they did not violate the Fourteenth Amendment.6 The court nevertheless found that the restrictions placed an unlawful burden on interstate motor traffic on specified highways. It issued an injunction against enforcement, with exceptions for bridges not constructed with sufficient strength to support the heavy trucks of modern traffic or too narrow to accommodate such traffic safely.7
The district court made detailed findings that 85 to 90 percent of trucks used in interstate transportation measured 96 inches wide and exceeded 20,000 pounds when loaded.8 It also found that the affected highways were of standard concrete construction capable of supporting heavier axle loads and that other states and expert organizations recommended higher limits.9 The Supreme Court took the case on appeal.10
Before adoption of the 1933 Act, South Carolina had set different weight limits in 1924 and 1930.11 A commission appointed in 1931 recommended the current restrictions after reviewing data from the state engineer who had constructed the highways.12
Whether the weight and width limitations of South Carolina Act No. 259 have been superseded by the Federal Motor Carrier Act of 1935?13
Congress has not undertaken to regulate the weight and size of motor vehicles in interstate motor traffic, leaving undisturbed whatever authority in that regard the states have retained under the Constitution.14
No. The district court ruled that the challenged provisions of the statute have not been superseded by the Federal Motor Carrier Act of 1935.1516 Appellees do not challenge the ruling of the district court that Congress has not undertaken to regulate the weight and size of motor vehicles in interstate motor traffic.17 The suit was brought in part on the ground that the provisions had been superseded by the Federal Motor Carrier Act of 1935, but the court rejected that claim after hearing evidence.18
The weight and width limitations of South Carolina Act No. 259 have not been superseded by the Federal Motor Carrier Act of 1935.19
Whether the limitations violate the Due Process Clause of the Fourteenth Amendment?20
State regulations of motor vehicle weight and width on highways do not violate the Fourteenth Amendment. Such regulations constitute an exercise of the state's power to regulate the use of its highways so as to protect them from injury and to insure their safe and economical use.21
No. The district court adopted as its own the ruling of the state Supreme Court in State ex rel. Daniel v. John P. Nutt Co. that the challenged provisions do not violate the Fourteenth Amendment.22 The Supreme Court affirmed that the regulatory measures taken by South Carolina do not infringe the Fourteenth Amendment.23
The limitations do not violate the Due Process Clause of the Fourteenth Amendment.24
Whether the limitations impose an unconstitutional burden on interstate commerce?25
The commerce clause permits non-discriminatory state regulations of the use of state highways to promote safety and conserve their use, applicable alike to vehicles moving in interstate commerce and those of its own citizens, so long as the means chosen are reasonably adapted to the end sought, and courts will not substitute their judgment for that of the legislature if the choice has a rational basis.26
No. The district court held that the weight and width prohibitions place an unlawful burden on interstate motor traffic passing over specified highways of the state.27 The Supreme Court reversed because the regulations are within the state's legislative power.28 South Carolina has built its highways and owns and maintains them.29 The present regulations must be applied alike to interstate and intrastate traffic.30
The choice of a gross weight limitation rests on convenience of application.31 Support for the limitation comes from the state's prior experience with higher limits in 1924 and 1930, the 1931 commission recommendation, and the state engineer's advice that a lower limitation was necessary for preservation of highways without center joints.32 Those highways tend to develop cracks and cannot support wheel loads in excess of 4,200 pounds on the inner edge.33 The record fails to exclude the possibility that the legislative choice has a rational basis.34
The width limitation of 90 inches has been in force since 1920 with highways adapted to vehicles of that width.35
The limitations do not impose an unconstitutional burden on interstate commerce.36