In the case of United States v. Western Pacific Railroad Co. (352 U.S. 59 (1956)), the military was shipping napalm and there was a dispute over how much Western Pacific could charge. Even though shipping rates were established by the Interstate Commerce Committee (ICC), Western Pacific took their case directly to Federal District Court, instead of asking for adjudication through the ICC. The military wanted the case heard by the ICC.

  • The US Supreme Court found that the Federal District Court theoretically had the jurisdiction to hear the case because it involved interstate commerce.
  • However, the Court found that the case was better handled in the ICC.
    • The ICC possessed acknowledged expertise in this issue and understood common trade practices, so they should be allowed to make a pronouncement on the dispute.
      • Does it make a difference if the Agency only has experts in the technical issue, and no experts in the legal issue? (See Western Pacific Far East Conference v. United States (342 U.S. 570 (1952)).
  • The Court ordered the Federal District Court to drop the case, and invited the parties to take their dispute to the ICC.
    • The Court noted that if a party was not satisfied with the ICC decision, they could always appeal in Federal Appellate Court.

Basically, the doctrine of primary jurisdiction requires that a dispute that fits within the jurisdiction of an Administrative Agency should be taken first to that Agency, even if the case in theory could be taken into court.

  • This decision was based on the idea that the Administrative Agency’s have greater technical expertise on the issue. See also Texas & Pacific Railway v. Abilene Cotton Oil Co. (204 U.S. 426 (1907)), which came to the same conclusion, but was decided on the fact that a Federal Agency can provide more uniformity to the law than a single Federal District Court can.