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Law School Case Brief

United States v. Standard Oil Co. - 332 U.S. 301, 67 S. Ct. 1604 (1947)

Rule:

Perhaps no relation between the government and a citizen is more distinctively federal in character than that between it and members of its armed forces. To whatever extent state law may apply to govern the relations between soldiers or others in the armed forces and persons outside them or nonfederal governmental agencies, the scope, nature, legal incidents, and consequences of the relation between persons in service and the government are fundamentally derived from federal sources and governed by federal authority.

Facts:

A soldier in the Army of the United States was injured by a motor truck, through negligence of the driver. The expenses of his hospitalization were borne by the United States; and he continued to receive his Army pay during the period of his disability. The United States brought suit in a federal district court against the owner and driver of the truck as tort-feasors to recover the amounts expended for hospitalization and soldier's pay during the period of disability, as for loss of the soldier's services. The district court found in favor of the government; however, the court of appeals reversed.

Issue:

Was the creation or negation of an independent liability owing directly to the government for deprivation of the soldier's services and indemnity for losses incurred in caring for the soldier after he was injured by the company to be determined by state law?

Answer:

No

Conclusion:

The Court found the issue as one of first impression. The Court, finding the Erie doctrine inapplicable, held that the creation or negation of an independent liability owing directly to the government for deprivation of the soldier's services and indemnity for losses incurred in caring for the soldier after he was injured by the company was not a matter to be determined by state law. The Court stated that the government-soldier relationship was distinctively and exclusively a creation of federal law. Nevertheless, the Court refused to consider the issue as to what the proper policy was concerning the company's liability. The Court concluded that whatever the merits of the policy was its conversion into law was a subject for congressional action and not that of the Court's.

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