subsequent reversals of decisions which were exceedingly
popular at the time, however, not only constituted sound law but
promoted the public interest, for they established that body of law
which has made possible the present more comprehensive system of Federal
regulation of railroads.

* The cases of particular interest were: Munn vs. Illinois, 94
U.S. 114; Peik vs. Chicago and Northwestern Railway Company, 94 U.S.
164; and Chicago, Burlington and Quincy Railway Company vs. Cutts, 94
U.S. 155.

Meanwhile the demand for regulation was gaining strength in the Eastern
States, but for somewhat different reasons. The farmers of New England,
New York, and the Eastern region in general had not particularly
sympathized with the Granger legislation; they already had great
difficulty in competing with the large Western farms, and a reduction
in rates to the seaboard would have made their position even less
endurable. This attitude was unquestionably selfish but entirely
comprehensible. The agitation for railroad reform in the East came
chiefly from the manufacturing and commercial classes. Here the main
burden of the complaint was the railroad rebate. This was a method of
giving lower rates to large shippers than to small--charging the favored
shipper the published rate and then, at stated periods, surreptitiously
returning part of the payment. This was perhaps the most vicious abuse
of which the railroads have ever been guilty. That the common law
forbade the practice and that it likewise violated the implied contract
upon which the railroad obtained its franchise was hardly open to
dispute; yet up to 1887 no specific law in this country prohibited the
practice. For many years the rebate hung over the American business
world, a thing whose existence was half admitted, half denied, a kind
of ghostly economic terror that seemed persistently to drive the small
corporation to bankruptcy and the large corporation to dominating
influence. The Standard Oil Company was the "monster" that was believed
especially to thrive upon this kind of sustenance, though this was by no
means the only industry that maintained such secret relations with the
railroads; the Carnegie Steel Corporation, for example, accepted
rebates almost as persistently. It was not until 1879, when the Hepburn
Committee in New York State had its hearings, that all the facts
concerning the rebate were exposed officially to public view. The
contracts of the Sta