Supreme Court of the United States · 1947 · Federal Courts
Federal Courtsfederal common lawindependent federal judicial decisionClearfield doctrineErie limitsgovernment-soldier relationshipfederal fiscal policyjudicial restraint
Facts
A Standard Oil truck driven by Boone struck and injured John Etzel, a soldier, in Los Angeles in February 1944. The United States paid $123.45 for Etzel's hospitalization and continued his soldier's pay in the amount of $69.31 during his disability. Etzel later released the company and Boone from all claims arising from the accident in exchange for $300. The United States then sought to recover its own expenditures from respondents on the theory that their tort interfered with the government-soldier relationship and caused loss to the Government.
Issue
Whether the United States may recover from private tortfeasors, absent congressional authorization, the amounts it spent for a soldier's hospitalization and continued pay after they injured him. The case also presented whether that question is governed by state law or by federal law.
Rule
Questions concerning the legal incidents and protection of the government-soldier relationship are matters of federal, not state, law. But where the asserted liability would create a new federal fiscal obligation requiring reimbursement to the United States, and Congress has not acted, federal courts should not create that liability by judicial decision.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Tacoma, Washington, a delivery van owned by Harbor Crest Logistics struck Army sergeant Elena Ortiz while she was walking between duty assignments. The United States paid for her medical treatment at a military hospital and continued her pay during her recovery, then sued Harbor Crest in federal court to recover those sums. Harbor Crest argues that Washington tort law controls because Congress has not enacted a statute on point.
Which is the strongest response to Harbor Crest's argument?
Explanation. The majority held that the scope, nature, and incidents of the relationship between the United States and members of its armed forces are fundamentally derived from federal sources. Therefore, Erie does not require application of state law to determine whether interference with that relationship creates liability. Federal courts may make an independent federal choice of law in such distinctively federal matters.