Wycoff Co., Inc. v. Public Service Commission of Utah
195 F.2d 252 · Court of Appeals for the Tenth Circuit · 1952
Facts
Wycoff Company, an interstate motor carrier of motion picture films, refused to acknowledge the jurisdiction of the Public Service Commission of Utah over its transportation activities beginning and ending wholly within Utah. Films originate nationally, are sent to Salt Lake City exchanges for processing, and then distributed to Utah exhibitors under contracts that maintain distributor control and continuous movement. The trial court found these in-state movements to be intrastate commerce.
Issue
Does the transportation of motion picture films from regional distributing exchanges within a state to exhibitors within that same state, and subsequently between exhibitors, constitute intrastate commerce subject to state regulation, or is it an integral part of continuous interstate commerce?
Holding
The court reversed the lower court's decision, holding that the entire transportation of films from national distributors, through regional exchanges, to various exhibitors within a state, and back to the exchange, constitutes continuous interstate commerce, not subject to state regulation.
Rule
If there is a continuing intent for goods to be transported to a designated final destination, the entire transportation remains interstate commerce, even if there are temporary stoppages en route for purposes like processing or allocation. The nature of the shipment is not determined by title passage or local bills of lading.
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