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The recent growth, like Jonah's gourd, of the motor bus industry and the Supreme Court's decisions upon it in the last few, years, indicate another gap for the filling of which, by the direct operation of Federal authority, demand is becoming more and more imperative. In Buck v. Kuykendall,45 and Bush v. Maloy,46 the Supreme Court held that bus lines carrying through interstate passengers only were not subject to the state commissions' authority in the matter of certificates of public utility and convenience, holding that the "direct burden" prohibition

The Interacting Areas of Regulatory Authority in Public Utilities