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When the act of a public officer is authorized or has been adopted by the sovereign power, whatever the immunities of the sovereign, the agent thereafter cannot be pursued.
During wartime, naval officers of the federal government captured the defendant fishing boats. The owners contested the forfeiture proceedings on the ground that the boats were neutral vessels used in coastal fishing for the daily market and were not liable to capture. The district court held that the detention of the fishing boats was unlawful and awarded damages to the owners of the fishing boats. The federal government appealed, claiming that only the persons who captured the fishing boats should be held liable and that the damage awards were excessive.
The Court held that the federal government was liable for the detention of the fishing boats but that the damage awards were excessive. The Court ruled that the captors were not liable because they were public officers and the federal government adopted their acts by instituting forfeiture proceedings against the vessels. However, the compensatory damage awards were excessive because the lower court gave undue weight to certain documentary evidence regarding the value of the fishing boats. Accordingly, the court reversed the decrees of the lower court and remanded the cases for further proceedings.