Western Union Telegraph Co. v. Speight
Headline: Court reverses state verdict, rules telegraphic messages routed through another State are interstate commerce, and bars recovery for emotional harm after a mistaken message delivery.
Holding: The Court held that a telegraphic message routed through another State is interstate commerce as a factual matter, and therefore the trial judge properly ordered a nonsuit, reversing the State court's judgment.
- Blocks recovery for emotional harm when a telegram is sent across state lines.
- Treats routing through another State as interstate commerce based on actual transmission.
- Leaves open liability for unreasonable routing or other wrongful conduct by the company.
Summary
Background
A woman named Rosemary received a telegraph about her father's death that said the funeral was the next day, but the delivered message was dated a day earlier and caused her to miss the funeral. The message was sent from Greenville, North Carolina, and routed through Richmond and Norfolk in Virginia to Roanoke Rapids, the local delivery point. At trial a jury found the company routed messages through Virginia to evade North Carolina law and awarded the plaintiff a verdict, but the trial judge set that verdict aside and ordered a nonsuit; the State Supreme Court later directed judgment for the plaintiff.
Reasoning
The Court asked whether the routing made the message an interstate transmission. It held that when a message actually passes through another State, that fact makes it interstate commerce as a matter of fact. The Court found the Richmond route had been used for years because it was quicker and cheaper, and there was no proof the company purposely arranged the route to evade state law. The Court therefore agreed the trial judge was correct to set aside the verdict and order a nonsuit.
Real world impact
The decision means people seeking only emotional damages after a mistaken telegram may be blocked if the message was sent across state lines, even when sender and recipient are in the same State. The opinion also explains that if a company used an unreasonable route or otherwise acted wrongfully, a different kind of liability could still arise. This ruling reverses the State court's judgment.
Dissents or concurrances
Justice Pitney agreed with the result and concurred in the Court's decision.
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