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Ouachita & M.R. Packet Co. v. Aiken, 121 U.S. 444, 7 S.Ct. 907, 30 L.Ed. 976

Facts

The appellants, owners of steamboats operating between New Orleans and other ports, filed a bill against the administratrix of Joseph A. Aiken and the city of New Orleans, claiming that the wharfage rates imposed were unreasonable and effectively duties of tonnage, violating the Constitution. The city had adopted ordinances regulating wharfage rates, which were subsequently leased to Joseph A. Aiken & Co. The plaintiffs contended that the rates were inflated due to conditions imposed on the lessees, which included maintaining the wharves and paying the city a substantial annual fee.

The bill alleges that on the seventeenth of January, 1875, the council of the city of New Orleans adopted an ordinance ‘fixing and regulating charges for wharfage, levee, and other facilities afforded by the city of New Orleans to commerce,’ by which ordinance, among other matters and things, it was ordained that the wharfage dues on all steam-boats shall be fixed as follows: ‘NOT OVER FIVE DAYS, TEN CENTS PER TON, and each day thereafter, five dollars per day; boats arriving and departing more than once a week, five cents per ton each trip; boats lying up for repairs during the summer months, to occupy such wharves as may not be required for shipping, for thirty days or under, one dollar per day.’

Issue

Are the wharfage rates charged by the city of New Orleans and its lessees excessive and unconstitutional under the U.S. Constitution?

The point raised by the complainants is that the rates of wharfage proposed by the lessees were necessarily enhanced by the condition requiring them to erect new wharves, to maintain electric lights, and to pay the city $40,000 per annum for the maintenance of a harbor police, and the payment of salaries to wharfingers, etc.

Rule

Charges for wharfage must be reasonable and cannot be considered duties of tonnage, which are prohibited by the Constitution. The reasonableness of such charges is determined by local state laws.

Charges for wharfage may be graduated by the tonnage of vessels using a wharf; and that this is not a duty of tonnage, within the meaning of the constitution, has been distinctly held in several cases.

Analysis

The court analyzed the evidence presented by both parties regarding the reasonableness of the wharfage rates. It found that the rates were established under the city's charter and were intended to cover the costs of maintaining and improving the wharves. The court concluded that the charges were not exorbitant and served the purpose of providing necessary facilities for commerce.

The court below declared ‘that the exactions of wharfage are substantially expended for the benefit of those using the wharves, and that the proof does not satisfy us that the rates are exorbitant or excessive.’

Conclusion

The court affirmed the decision of the lower court, ruling that the wharfage charges were reasonable and did not violate the Constitution.

As the only question determinable in this suit is whether the charges of wharfage complained of were or were not contrary to the constitution or any law of the United States, and as it is clear that they were not, the decree of the circuit court must be affirmed.

Who won?

The city of New Orleans and its lessees prevailed in the case because the court found the wharfage rates to be reasonable and within the city's authority to impose.

The court found that the rates were established under the city's charter and were intended to cover the costs of maintaining and improving the wharves.

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