POWERS OF CORPORATIONS CREATED BY CONGRESS 699 land,^^ in which Justice Bradley referred to the exercise of the power of Congress over interstate commerce in the construction of the Cumberland national road and similar works and the more recent exercise of that power, though mostly through national territory, in the establishment of railroad communication with the Pacific coast. He quoted the Minnesota Rate cases, followed in Houston, East &° West Texas Railway Co. v. United States,^^ and concludes (page 594): "It has, therefore, been determined that Congress, under its power to regulate commerce, may itself build railways or provide for govern- ment railways by delegation of power to corporations. The government may also provide for transportation of its mails, its armies, and its property by any means it chooses to select. Under these ample powers it may provide its own instrumentalities of transportation, or may make use of existing instrumentalities." During the last three months there has been a series of articles in the Michigan Law Review by Professor Myron W. Watkins, of the University of Missouri.^^ He examines in detail the decisions of the Supreme Court in the cases of the banks of the United States and the national banks, the Pacific Railroad cases, the bridge cases, the ferry cases, the cases on the incorporation and regulation of telegraph companies and express companies, and the cases on the regulation of rates and of the operation of the instruments or instrumentahties of interstate commerce, and the jurisdiction over questions of liability to employees and to the public, and upon the effect of the federal statutes upon monopolies and restraint of trade. Referring to the laxity and diversity of the regulation of corporations created by the various states, he examines the question whether compulsory federal incorporation of all corporations engaged in interstate commerce is not a constitutional remedy, and the conclusion on this last point is that the enactment of a national incorporation law, if "backed by a fair proportion of the business community (and there seems every reason to believe that it would even now have the support of a representative group of men in business and professional life), and if Congress by its first action evidences a disposition to promote the « 2LWaU. (U. S ) 456 (1874). ^ 234 U. S. 342 (1914). " "Federal Incorporation," 17 Mich. L. Rev. 64, 145, 238, November and De- cember, 1918, and January, 1919.
