Davis v. Corona Coal Co.

Background

On March 3, 1923, the Director General of Railroads sued a coal company in a New Orleans city court for damage to a railroad wharf on January 9, 1920, while the wharf was under federal control. The coal company pleaded Louisiana’s one‑year prescription under Civil Code article 3536. The city court and the court of appeal accepted that defense and the state supreme court denied review, so the case came to this Court on certiorari.

Reasoning

The Court addressed whether a state statute of limitations could bar a suit the United States brought (through its Director General) for a loss that occurred while the Government controlled the property. The opinion relied on earlier decisions, including Dupont De Nemours & Co. v. Davis, holding that the Director General is not barred by state statutes when suing on behalf of the United States, and repeated the rule that the United States does not waive sovereign rights unless it is plainly stated. The Court explained that the Federal Control Act made carriers subject to existing laws but did not import state limitations that would prevent the Government from collecting its claims. The Court also noted prior rulings that a state limitation cannot bar the United States in federal courts, and applied those principles to avoid letting a state’s control of its courts defeat a constitutional right to sue.

Real world impact

The Court reversed the state courts’ rulings, holding that Louisiana’s one‑year prescription could not be used to stop the federal claim. As a result, claims the Government brings for losses during federal control may proceed in state courts without being defeated by that state time bar, and the United States’ immunity and rights were not found to be waived here.