National Railroad Passenger Corp. v. National Assn. of Railroad Passengers

In National Railroad Passenger Corp. v. National Assn. of Railroad Passengers, 414 U. S. 453, 458, 460 (1974), there was a private cause of action provided in favor of certain plaintiffs concerning the particular provision at issue. It was in this context that we referred to "a frequently stated principle of statutory construction . . . that when legislation expressly provides a particular remedy or remedies, courts should not expand the coverage of the statute to subsume other remedies." 414 U. S., at 458. In addition, there was specific support in the legislative history of the Amtrak Act for the proposition that the statutory remedies were to be exclusive. Id., at 458-461. In National R.R. Corp. v. National Ass'n of R.R. Passengers, 414 U.S. 453, 456, 94 S.Ct. 690, 692, 38 L.Ed.2d 646 (1974) (Amtrak), the Court considered whether respondents had a private cause of action to challenge certain train discontinuances in light of 307(a) of the Rail Passenger Service Act of 1970 ("Amtrak Act"), 84 Stat. 1327, codified at 45 U.S.C. 501 et seq. That section vested the district courts with jurisdiction over violations of the Amtrak Act as well as created a "public cause of action, maintainable by the Attorney General, to enforce the duties and responsibilities imposed by the Act." Amtrak, 414 U.S. at 457, 94 S.Ct. at 693. In addition, section 307(a) provided a private cause of action, as in the present case, but only under certain circumstances. Id. at 460, 94 S.Ct. at 694. Respondents argued in that case that the court should imply a private cause of action because they "are the intended beneficiaries of the Act." Id. The district court dismissed for lack of standing. The court of appeals reversed and held that respondents, who represented railroad passengers, had standing and that 307 did not bar a private suit. The Supreme Court reversed. In reaching its decision, the Court was influenced by the existence of a carefully crafted remedial scheme that included both public and private, albeit limited, enforcement. The Court relied heavily on the "frequently stated principle of statutory construction ... that when legislation expressly provides a particular remedy or remedies, courts should not expand the coverage of the statute to subsume other remedies." Amtrak, 414 U.S. at 458, 94 S.Ct. at 693 (citing Botany Mills v. United States, 278 U.S. 282, 289, 49 S.Ct. 129, 131-32, 73 L.Ed. 379 (1929)). In National Railroad Passenger Corp. v. National Ass'n of Railroad Passengers, 414 U.S. 453, 94 S.Ct. 690, 38 L.Ed.2d 646 (1974) (Amtrak ), an association of railroad passengers challenged the discontinuance of certain passenger lines as violative of the Rail Passenger Service Act. In reaching its conclusion that the Act does not imply a private cause of action of this type, the Court focused principally on the fact that the Act specifically permits enforcement suits by the Attorney General or, in cases involving a labor agreement, by employees. It was argued that the authorization of the public cause of action and the very narrow private right of action "should not be read to Preclude other private causes of action for the enforcement of obligations imposed by the Act." Id. at 457, 94 S.Ct. at 693. Since the action was brought by the intended beneficiaries of the Act, it was contended that the Court should therefore imply a private cause of action in their favor. The Court disagreed, reasoning that when legislation expressly provides a particular remedy or remedies, courts should not expand the coverage of the statute to subsume other remedies. "When a statute limits a thing to be done in a particular mode, it includes the negative of any other mode." This principle of statutory construction reflects an ancient maxim Expressio unius est exclusio alterius. Since the Act creates a public cause of action for the enforcement of its provisions and a private cause of action only under very limited circumstances, this maxim would clearly compel the conclusion that the remedies created in 307(a) are the exclusive means to enforce the duties and obligations imposed by the Act. Id. at 458, 94 S.Ct. at 693. In National Rail Passenger Corp. v. National Association of Rail Passengers, 414 U.S. 453, 94 S.Ct. 690, 38 L.Ed.2d 646 (1974), the National Association of Rail Passengers (NARP) sought to enjoin the discontinuance of passenger rail service. NARP alleged that discontinuation would violate the Rail Passenger Act of 1970 (Amtrak Act). The Supreme Court held that NARP lacked standing under 307(a) of the Amtrak Act, 45 U.S.C. 547. 307, by its terms, gave the district court jurisdiction over suits brought by the Attorney General, and certain labor organizations, to prevent violations of the Amtrak Act. The statute did not create a private cause of action. The Court refused to imply one because the statute already provided a remedy for violation of the Act. In light of the language of 307(a) and its legislative history, the Court held that to imply a private remedy "would completely undercut the efficient apparatus that Congress sought to provide" for the destitute railroads covered by the Amtrak Act, 414 U.S. at 463, 94 S.Ct. at 696