North American Transportation & Trading Co. v. Morrison

Background

Donald Morrison, a man who said he lived in Minnesota, sued a Chicago-based transportation company after it failed to carry him and his baggage from Seattle to Dawson City in the Northwest Territory of Canada. He sought repayment of his $200 fare, return expenses, lost baggage, some Seattle wages, and large sums he said he would have earned in Dawson City had he arrived and obtained work. The company removed the case from state court to federal court, and the federal court’s power to hear the case depended on whether the claimed losses met the required dollar amount.

Reasoning

The Court focused on whether the plaintiff could recover the speculative earnings he hoped to make in Dawson City. The Court said those claimed future wages were too remote and uncertain because Morrison had no shown ties, job offers, or definite plans at Dawson City, and his hoped-for work could not be proved. The Court also held that Morrison could not use claims assigned to him by other travelers to create federal jurisdiction because the assignors’ citizenship was not stated and the law limits suits brought by assignees when the original owners could not themselves have sued in federal court. The Court concluded the federal court lacked proper jurisdiction for the full amount claimed.

Real world impact

People can recover real, provable out-of-pocket losses from a carrier that breaks a transport contract, but they cannot collect speculative future earnings based solely on hope. Plaintiffs also cannot aggregate unnamed or unproved assigned claims to force a federal forum; the case is sent back to state court for further handling.