Western Union Telegraph Co. v. Chiles

Background

A sailor serving as a gunner aboard the U.S.S. Abarenda at the Norfolk Navy Yard did not receive a telegram addressed to him. The message was sent from Richmond to Portsmouth, the usual office for the navy yard, but never reached him aboard the ship. He sued the telegraph company in Portsmouth under a Virginia law that imposed a $100 penalty when companies failed to forward or deliver telegrams promptly. The trial judge refused the telegraph company’s request to instruct the jury that the Virginia law had no force inside the navy yard, and the jury returned a verdict for the sailor; the state courts affirmed.

Reasoning

The core question was whether a Virginia statute can operate inside the Norfolk Navy Yard. The Court reviewed the yard’s history and found that the Commonwealth ceded the land and its jurisdiction to the United States by acts and executive deeds. The Constitution gives Congress exclusive legislative power over places purchased for docks and yards. That exclusive legislative power includes exclusive jurisdiction, so state laws generally cannot apply inside the yard. The Court explained that if penalties for conduct inside the yard are desired, Congress—not the State—must establish them, and therefore reversed the state judgment.

Real world impact

The decision prevents states from enforcing their statutes or penalties within federally owned navy yards. It affects sailors, telegraph companies, and others who work or receive services on ships or property inside such federal installations. The ruling leaves regulation and any penalties for conduct inside the yard to Congress and federal law. This case does not decide how state law applies to contracts made outside or before entry into the yard.