331 U.S. 218 (1947)
Respondents Santa Fe Elevator Corp. and other entities operated public grain warehouses in Illinois under licenses issued by the Secretary of Agriculture pursuant to the United States Warehouse Act.1 The Rice partnership, an owner, shipper, and dealer in grain, served as one of their customers, while the Illinois Commerce Commission held regulatory jurisdiction over public grain warehouses under state law.2
In 1944 Rice filed a complaint with the Illinois Commerce Commission alleging that respondents maintained unjust and unreasonable rates, discriminated in storage rates in favor of the federal government, operated in dual conflicting positions as warehousemen and grain dealers, failed to provide reasonable and adequate facilities, issued securities and entered affiliate contracts without prior approval, operated without a state license, abandoned service without consent, failed to file and publish rate schedules, and mixed public grain with inferior grades.3
Respondents moved to dismiss the complaint on the ground that the federal Warehouse Act superseded state authority.4 The Commission denied the motion and set the matter for hearing.5 Respondents then filed suits in federal district court seeking to enjoin further Commission proceedings and any enforcement actions by the Illinois Attorney General.6
The district court granted petitioners' motions to dismiss the suits.7 The Circuit Court of Appeals reversed.8 The Supreme Court granted certiorari because of the public importance of the questions presented.9
The United States Warehouse Act was enacted in 1916 and originally made federal regulation subservient to state warehouse laws, including by requiring bonds conditioned on compliance with state obligations.10 Congress amended the Act in 1931 to delete the state-law bond requirement and to provide that the Secretary's power, jurisdiction, and authority shall be exclusive for persons holding federal licenses.11
The complaint also raised three additional matters not expressly addressed in the federal Act.12 These were failure to obtain prior Commission approval for management, construction, and financial contracts with affiliates.13 They also included failure to obtain approval for contracts and leases with other public utilities.14 Finally they included failure to obtain approval for issuance of long-term securities.15
Whether the 1931 amendments to the United States Warehouse Act render the Secretary of Agriculture's power, jurisdiction, and authority exclusive for federally licensed warehousemen on matters addressed by the federal statute?16
When Congress enacts a federal regulatory scheme for a field traditionally occupied by the states.17 It then amends the statute to delete references to state law compliance and to declare the federal agency's power exclusive for licensees.18 The federal policy occupies the field on every subject the statute addresses.19 It preempts state regulation even in the absence of direct operational conflict.20
Yes. The 1931 amendments removed the bond condition requiring compliance with state warehouse laws and inserted mandatory language that the Secretary's power, jurisdiction, and authority shall be exclusive for every person holding a federal license.21 Respondents operate under licenses issued by the Secretary pursuant to the United States Warehouse Act.22 Rice's 1944 complaint before the Illinois Commerce Commission presented nine specific charges.23 These included unjust rates, rate discrimination favoring the federal government, dual warehouseman-dealer conflicts, mixing of grain grades, inadequate facilities, operation without a state license, unauthorized abandonment of service, and failure to file rate schedules.24 Each charge the federal Act regulates through rate disclosure rules, nondiscrimination duties under section 13, ownership disclosure requirements, grading and mixing standards under sections 15 and 16, suitability determinations under section 3, licensing and revocation authority under sections 4, 5, and 25, and publication mandates in the regulations.25
Because Congress legislated on each subject and made its scheme exclusive, Illinois may not impose additional or different requirements on these federally licensed operators.26
The 1931 amendments preempt Illinois regulation of the nine matters addressed by the federal Warehouse Act for operators holding federal licenses.27
Related opinions on this issue
Joined by Justice Rutledge
Justice Frankfurter dissented.28 He argued that the 1931 amendment should be construed only to bar state action that actually conflicts with or duplicates the limited licensing functions the Secretary can exercise.29 This construction would leave intact longstanding state regulatory powers such as rate fixing that the federal Act does not assume.30
He stressed that the federal license is optional.31 The Act imposes few affirmative duties.32 The legislative history shows no intent to create a regime of non-regulation outside the narrow federal sphere.33
He noted that the practical assumption is that Congress would permit its licensing authority to avail itself of the facilities of the established rate-fixing agencies of the States.34
Whether state regulation of rates, discriminatory practices, dual positions as warehousemen and dealers, mixing of grain, facility adequacy, licensing, abandonment of service, and rate publication is superseded for operators holding federal warehouse licenses?35
State laws that regulate subjects on which Congress has declared a federal policy through a licensing and enforcement scheme are displaced by the federal statute under the Supremacy Clause once the federal agency is given exclusive authority over licensees.36
Yes. The federal Warehouse Act addresses rates through mandatory filing and prohibitions on unreasonable charges.37 It addresses discrimination through the section 13 duty to receive grain without preference.38 It addresses dual positions through ownership disclosure rules.39
It addresses mixing through sections 15 and 16 and implementing regulations.40 It addresses facility adequacy through the Secretary's suitability and care standards.41 It addresses licensing and abandonment through issuance, suspension, and revocation powers.42 It addresses rate publication through conspicuous posting requirements.43
Respondents hold federal licenses and therefore fall within the exclusive federal jurisdiction created by the 1931 amendments.44 The Illinois Commerce Commission's authority to enforce parallel state standards on these exact subjects therefore cannot be invoked against them.45
State regulation of the listed subjects is superseded for federally licensed warehousemen.46
Whether state requirements for prior approval of affiliate contracts, securities issuances, and leases remain applicable to federally licensed warehousemen when those subjects receive no express treatment in the federal Warehouse Act?47
Yes. The federal Warehouse Act contains no provisions governing prior approval of management or financial contracts with affiliates, contracts with other utilities, or issuance of long-term securities.50 The three additional charges in Rice's complaint therefore concern matters into which Congress has not moved.51 Any hypothetical future conflict between a state order and federal licensing authority remains speculative at this stage and does not justify displacing state authority now.52
State requirements for prior approval of affiliate contracts, securities issuances, and leases remain applicable to federally licensed warehousemen.53