United States v. Commonwealth & Dominion Line, Ltd.

Background

This case involves a collision at sea between a U.S.-owned steam collier named Proteus and the British steamer Port Phillip. The owner of the Port Phillip sued the United States to recover damages. The lower courts agreed that the Proteus was at fault, but the Court of Appeals allowed interest on the damage award and the United States appealed that part of the judgment.

Reasoning

The Court considered whether a special 1923 statute that lets private shipowners sue the United States for collision damages also allows recovery of interest on those damages. The Court compared this case to a recent decision that interpreted a similar statute and denied interest. It explained that when Congress gives permission to sue the Government in narrow statutory language, the words must be taken strictly. The Court distinguished an earlier case where the Government voluntarily sued and was treated like a private party; here the Government was brought into court under the special statute and did not impliedly accept broader liability. A cross-claim by the Government in this suit was held to be only an incident of the statutory proceeding and did not expand the remedies Congress authorized.

Real world impact

Because of this ruling, private shipowners who win damage awards against the United States under the 1923 statute may not collect interest on those awards. The decision limits the total money recoverable in such government collision suits. The Court reversed the lower court’s allowance of interest and sent that part of the decree away.