Vance v. W.A. Vandercook Company

170 U.S. 468 (1898)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

P shipped 68 packages of wine. It was seized in South Carolina and eventually found its way into the hands of Ds. P sued Ds to recover the property. It is agreed by all that the wine was worth $1,000. P also sought special damages of $10,000 in his pleadings and as such filed the suit in federal court under diversity jurisdiction for damages in excess of $2,000, the amount in controversy for diversity jurisdiction. Ds claimed that the acts by them were performed under the authority of a law of South Carolina. In South Carolina, special damages required that the plaintiff incur some kind of direct injury. D moved to dismiss for lack of any possibility that P would satisfy the jurisdictional amount. The facts found by the court were: 'That the property described in the complaint is the property of the plaintiff, and that the value thereof is the sum of one thousand dollars, and that the damages to the plaintiff from the detention of the said property by the defendants is the sum of one thousand dollars.' Ds appealed.