EDITORIAL DEPARTMENT RATE REGULATION. "Regulation of Rates to be Charged by Public Service Com panies, II, Railroads," by O. H. Myrick, Central Law Journal (V. Ixvii, p. 317). RATE REGULATION. " Rate Regulation as Affected by the Distribution of Govern mental Powers in the Constitutions," by Robert P. Reeder, University of Pennsylvania Law Review and American Law Register (V. Ivii, p. 59). This is an elaborate article with numer ous citations and quotations attempting to show that " within their respective jurisdictions and within constitutional bounds, both Congress and the state legislatures may limit the charges for railroad transportation, either specifically or by definite general rules;
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and that if the legislative department of government establishes such rules it may empower a commission to name specific rates in accordance therewith; but that, on the other hand, such rules may be established only by the legislative department, and until they are so established no commission may constitutionally ordain specific rates." It furthermore considers the question whether the statutes which empower commissions to name specific rates do establish definite prin ciples of which the commissions are simply called upon to state the specific applications or whether by those statutes the attempt is made to entrust to the commissions a dis cretion which is so broad as to be uncon stitutional.
