and Wabash, St. Louis & Pacific Railway Co. v. Illinois (1886) had established the rights of the state and federal governments to regulate railroads to protect the public interest. Interstate service was largely regulated by the federal Interstate Commerce Commission (ICC), which had limited intrastate authority – it could prevent a railroad from abandoning service on a line, but could not regulate the quantity of service provided. State agencies, such as the Massachusetts Public Utilities Commission (PUC), had more regulatory power over intrastate service. Prior to 1933, railroad reorganizations rarely had negative effects on users (passengers and freight shippers), as receivership typically involved a deferment of debts rather than cuts to service. Management changes and a reduction in deferred maintenance sometimes even resulted in improved service for users. The Act of March 3, 1933 (the final day of Herbert Hoover's presidency) added three new sections to the Bankruptcy Act of 1898; Section 77 brought railroads under the Bankruptcy Act for the first time. Major amendments on August 27, 1935, attempted to streamline the bankruptcy process, as the complexity of railroads had resulted in protracted proceedings. The Depression and automobile competition made increasing revenues near-impossible, while the Railway Labor Act disallowed wage reductions. Since only major corridors tended to be profitable, lesser-used lines and stations were increasingly targeted for elimination during bankruptcy proceedings. New Haven bankruptcy On October 23, 1935, the New Haven petitioned the United States District Court for the District of Connecticut to begin bankruptcy proceedings under Section 77. The court appointed trustees for the railroad, who "tentatively" continued paying the Old Colony lease. The public largely saw the proceedings as a chance for the New Haven to escape its early-20th-century debt; Old Colony stock rose from 39 to 70 by March 1936. On June 1, 1936, the trustees rejected the Old Colony lease based on studies that found it unprofitable. As the Old Colony was merely a "bookkeeping device" with all railroad operations directed by the New Haven, the court ordered on June 3 that the New Haven continue to operate the Old Colony but on the Old Colony's account. The court also approved the Old Colony's petition to enter the same reorganization proceedings as the New Haven; on June 18, the three New Haven trustees were also designated trustees of the Old Colony. On June 1, 1937, the New Haven submitted its reorganization plan, under which the