Hartsville Oil Mill v. United States , is a United States Supreme Court

Supreme Court of the United States

The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 case in which the Court held that the jurisdiction of the Court of Claims

United States Court of Claims

The Court of Claims was a federal court that heard claims against the United States government. It was established in 1855 as the Court of Claims, renamed in 1948 to the United States Court of Claims , and abolished in 1982....

 was not enlarged by Congressional reference legislation when the court already had jurisdiction to hear the case under another section of the Judicial Code. Additionally the court held that modification to the contract in question was not by duress as there had not been an inadequate power in the courts to remedy the effects of the threatened actions.

Background

On September 26, 1918, the government made a contract with Hartsville Oil Mill, a cottonseed producer, which was replicated with several other cottonseed producers for the delivery of cotton linters. Cotton linters, a by-product of the cotton crushing process, were used by the government in World War I

World War I

World War I , which was predominantly called the World War or the Great War from its occurrence until 1939, and the First World War or World War I thereafter, was a major war centred in Europe that began on 28 July 1914 and lasted until 11 November 1918...

 for the production of explosives

Nitrocellulose

Nitrocellulose is a highly flammable compound formed by nitrating cellulose through exposure to nitric acid or another powerful nitrating agent. When used as a propellant or low-order explosive, it is also known as guncotton...

. Of the production of 2,250,000 pounds, 270,000 bales were on hand and inspected when armistice was declared in late 1918. At this time the government informed the producers that it intended to cancel the contract and would only accept 150,000 bales if the producers agreed to a contract modification. Faced with this repudiation of the contract, the producers agreed to the modification and sought recovery by petition to the U.S. Senate under Judicial Code § 145, the predecessor to 28 U.S.C. § 1492.

Case details

Following the passage of a Senate Resolution numbered 448 on March 23, 1922, referring Senate bill numbered 4479 March 3, 1922 to the Court of Federal Claims, the producers filed a case with the Court of Claims requesting they investigate the matter and report to the Senate. However, the Court of Claims determined that it held jurisdiction over the contract dispute under Judicial Code § 7 and heard the case under its Article III jurisdiction. While the producers alleged that they had been forced to agree to the modification of the contract under duress

Duress

In jurisprudence, duress or coercion refers to a situation whereby a person performs an act as a result of violence, threat or other pressure against the person. Black's Law Dictionary defines duress as "any unlawful threat or coercion used... to induce another to act [or not act] in a manner...

 of the government's threat of repudiation

Anticipatory repudiation

Anticipatory repudiation, also called an anticipatory breach, is a term in the law of contracts that describes a declaration by the promising party to a contract, that he or she does not intend to live up to his or her obligations under the contract....

 of the original contract, the Court of Claims held that there was no duress. They reasoned that the producers negotiated with the government for several weeks and that the government gave up concessions which constituted consideration for contractual purposes. As such, there was no duress as the plaintiffs had substantial time, prior to agreeing to the modification, to seek redress in a court of law for their claims under the original contract and that therefore the remedies at law

Legal remedy

A legal remedy is the means with which a court of law, usually in the exercise of civil law jurisdiction, enforces a right, imposes a penalty, or makes some other court order to impose its will....

 were not inadequate as to invoke the doctrine of duress.

Appeal

On appeal to the Supreme Court, the producers contested the Court of Claims findings of jurisdiction and on the element of duress in the contract, alleging a lack of jurisdiction, the existence of duress, and a lack of consideration for the contract. Writing for the court, Justice Harlan F. Stone affirmed the decision of the lower court and found against the producers on their claims. He argued that the Senate resolution referring the case to the Court of Claims had no effect on and did not enlarge its jurisdiction. The case is known for establishing the idea that the Court of Claims' jurisdiction under its judicial authority would supersede its congressional jurisdiction where the two conflicted.