The Paquete Habana

Supreme Court of the United States · Federal Courts

Federal Courtsprizesovereign liabilitydamagesprize casesUnited States as partyratificationadoption of officer acts

Facts

These cases involved fishing smacks that had been captured and libelled as prize of war. The United States filed the libels on its own behalf, alleged capture pursuant to presidential instructions, and sought forfeiture to the United States; it did not order the vessels released. After liability for capture had already been resolved, the remaining dispute concerned whether compensatory damage decrees could be entered against the United States and whether the commissioner's valuations of the vessels, fish, and interest were excessive. The commissioner largely adopted the owners' and Havana harbor master's valuations without reduction, including high fish prices during the blockade and interest at eight percent.

Issue

When the United States has adopted and prosecuted wartime captures in its own name, may a final compensatory damages decree be entered against the United States rather than the captors? Also, did the evidence support the commissioner's damage findings, or was further revision required?

Rule

If the act of a public officer is authorized or adopted by the sovereign power, the agent thereafter cannot be pursued; where, under the circumstances, the United States has submitted to the court's jurisdiction and the decree must run against someone, a compensatory damages decree may run against the United States. Findings on damages, even by a master or commissioner, may be revised when based chiefly on documentary evidence before the appellate court and when the record shows undue reliance on unsupported or inflated valuations rather than actual loss.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

During an armed conflict, Commander Elena Ortiz of the U.S. Navy seized three small coastal freight boats near Key West and they were brought into Miami for prize proceedings. The United States then filed libels in its own name, alleged the seizures were made pursuant to presidential instructions, and sought forfeiture of the boats and cargoes to the United States.

If the court later determines the seizures were unlawful and a compensatory damages decree must be entered, against whom should the decree run under the majority's rule?

Explanation. The majority reasoned that when the sovereign authorizes or adopts the act of a public officer, the agent cannot thereafter be pursued for that act. Here, the United States filed the libels on its own behalf, alleged presidential authorization, and sought forfeiture to itself, showing adoption of the seizures. Under those circumstances, if a decree is to be entered, it should run against the United States rather than the captor. (Derived from The Paquete Habana (n.d.).)