Western Union Telegraph Co. v. Wilson

Background

A person who sent a telegraph from Graham, Virginia, to East Radford sued the telegraph company after the message was delayed in transit and again delayed on delivery. The sender sought a $100 penalty that Virginia law allows when a dispatch is not sent or delivered “as promptly as practicable.” The company had filed an early demurrer and a general denial, and then—just before trial—offered a new plea saying the message had been routed through Washington and that an interstate mistake sent it to Cincinnati, so the state law could not apply to the out-of-state part.

Reasoning

The Court explained it cannot review a state-court judgment unless a federal question was necessarily decided by the state court. The record did not show why the state court refused to let the company file that late plea. The state court may have rejected the plea for purely local reasons—because it was offered too late or because it failed to address the second count—so the United States Supreme Court could not assume the state court had rejected the company’s federal-commerce argument on the merits.

Real world impact

Because the record left open reasonable state-law reasons for denying the plea, the Supreme Court dismissed the company’s appeal and did not decide the constitutional question. The lower-court judgment for the sender remained in place; the Court noted the delay was proved and that nothing in the record proved the message actually left the State.