That express companies cannot escape regulation by the interstate commerce commission on the ground that they are joint stock associations instead of corporations, was decided by the Supreme Court of the United States in the case of the Adams Express Company, which successfully resisted a suit brought by the government in the southern district of Ohio charging the company with violating the interstate commerce act. The statute in prohibiting certain practises, mentions "corporations" as being forbidden to engage in them, and the express company took refuge behind the fact that it was not a corporation. "It has been notorious for years," said Justice Holmes, who delivered the opinion, "that some of the great express companies have been organized as stock companies for the express reason, it seems, to evade this law." Pointing out that it was clearly the intent of Congress originally to include express companies, Justice Holmes added that if there were any doubt as to the original intent to include them, it had been removed by subsequent amendments to the law, which have applied it specifically to express companies.

Instructions to postmasters have been issued for handling of C. O. D. parcel post packages, and the regulations will be effective July 1. Charges on packages will be collected from addressees on and after that date, provided the amount on a single parcel does not exceed one hundred dollars. The fee for collection will be ten cents in parcel post stamps, to be affixed by the sender. This fee will also insure the package against loss to the actual value of the contents not exceeding fifty dollars. The sender will get a receipt showing the amount to be collected, the amount also appearing on a tag attached to the package. The addressee will receipt for the package on the tag, which will serve as an application for a money order. C. O. D. parcels may be accepted for mailing by rural carriers, and will be delivered by city and rural carriers and special delivery messengers. Such packages will not be mailable either to the Philippines or to the Canal Zone.

The power of the states to fix reasonable interstate rates on interstate railroads, until such time as Congress shall choose to regulate these rates, was upheld by the Supreme Court of the United States in the Minnesota freight and passenger rate cases. At the same time the court laid down far-reaching principles governing the valuation of railroad property for rate-making purposes. The decision, regarded as one of the most important ever announced by the court, has been under consideration for fourteen months. Railroad commissions from eight states, with the governors of all of them, filed briefs in support of the states in these cases, recognizing that the principles involved affected them all.

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June 21, 1913

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