Facts. The Defendant corporation, New York Central & Hudson River Railroad Co. (Defendant), together with a managing agent within the corporation, were convicted of violating a federal law prohibiting the payment of rebates. Specifically, the corporation was prosecuted for the payment of rebates to the American Sugar Refining Company arising out of shipments of sugar from New York to Detroit. The Defendant was prosecuted under the “Elkins Act”, 32 Stat. 847, which held a corporation criminally liable for unlawful acts of its agents.
Issue. Is a corporation criminally responsible for the unlawful acts of its agent acting within the scope of authority conferred upon them by the corporation?
New York Central & R.R. (Defendant) owned and operated a train. Brower (Plaintiff) was riding in a wagon loaded with goods. Defendant’s train hit Plaintiff’s wagon. The accident killed Plaintiff’s horse, destroyed his wagon, and spilled the goods. While Plaintiff was still confused from the accident, third parties stole his goods. Defendant had two railroad detectives on the train to protect Defendant’s belongings from thieves. The detectives did not assist Plaintiff. Plaintiff sued Defendant for damages resulting from the accident and sought recovery for the stolen goods. Defendant denied liability for the stolen goods because it was a result of third party intervention, which broke the causal chain. The trial court ruled for Plaintiff. Defendant appealed.