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of lowering them to the level of the lowest, the commissioners were directed to establish a schedule of maximum rates; and the charging of rates higher than these by any company after January 15, 1874, was to be considered prima facie evidence of extortion. Other provisions increased the penalties for violations and strengthened the enforcing powers of the commission in other ways. This act was roundly denounced at the time, especially in the East, as an attempt at confiscation, and the railroad companies refused to obey it for several years; but ultimately it stood the test of the courts and became the permanent basis of railroad regulation in Illinois and the model for the solution of this problem in many other States. The first Granger law of Minnesota, enacted in 1871, established fixed schedules for both passengers and freight, while another act of the same year provided for a railroad commissioner. In this instance also the companies denied the validity of the law, and when the state supreme court upheld it in 1873, they appealed to the Supreme Court of the United States. In the meantime there was no way of enforcing the law, and the antagonism toward the roads fostered by the Grange and the Anti-Monopoly party became more and more intense. In 1874 the legislature replaced the Act of 1871 with one modeled on the Illinois law of 1873; but it soon discovered that no workable set of uniform rates could be made for the State because of the wide variation of conditions in the different sections. Rates and fares which would be just to the companies in the frontier regions of the State would be extortionate in the thickly populated areas. This difficulty could have been avoided by giving the commission power to establish varying schedules for different sections of the same road; but the anti-railroad sentiment was beginning to die down, and the Legislature of 1875, instead of trying to improve the law, abandoned the attempt at state regulation. The Granger laws of Iowa and Wisconsin, both enacted in 1874, attempted to establish maximum rates by direct legislative action, although commissions were also created to collect information and assist in enforcing the laws. The Iowa law was very carefully drawn and appears to have been observed, in form at least, by most of the companies while it remained in force. In 1878, however, a systematic campaign on the part of the railroad forces resulted in the repeal of the act. In
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