King v. Order of United Commercial Travelers of America

Background

Mrs. King, the beneficiary of a $5,000 accidental-death policy, sued after her husband, Lieutenant King, died following an emergency landing and hours in cold water. The insurer refused payment because the policy excluded “death resulting from participation ... in aviation.” Mrs. King sued in a South Carolina court; the case was removed to federal district court. The district judge, finding no South Carolina precedent on the exclusion, applied state rules that ambiguities favor beneficiaries and that the immediate cause of death controls, and ruled for Mrs. King. A South Carolina Court of Common Pleas later reached the same result in a different case, but the Court of Appeals reversed in the present case, concluding King’s death resulted from participation in aviation. After certiorari, another Common Pleas court issued an opinion siding with the appeals court.

Reasoning

The central question was whether a federal court must treat an unpublished South Carolina trial-court decision as the State’s law. The Court reviewed the Rules of Decision Act, Erie, and related cases. It explained that South Carolina’s trial courts (Courts of Common Pleas) issue unpublished county decisions that are binding only on the parties and are not treated as precedents. Because those decisions are hard to find and carry little weight in South Carolina itself, the Court held the Court of Appeals did not err in declining to treat the Spartanburg trial decision as controlling. The Court did not decide who was right on the insurance coverage question.

Real world impact

The decision means federal judges in diversity cases may decline to follow isolated, unpublished state trial rulings when predicting state law. This affects insurance claimants, insurers, and lawyers who rely on local trial decisions. It is not a blanket rule; other states or different factual situations might require different treatment.