Order of United Commercial Travelers v. Wolfe
United States Supreme Court
331 U.S. 586, 67 S. Ct. 1355, 91 L. Ed. 1687, 173 A.L.R. 1107 (1947)
- Written by Mary Phelan D'Isa, JD
Facts
Wolfe, an Ohio citizen (plaintiff), sued the Order of United Commercial Travelers, an Ohio corporation (the society) (defendant), in a state court in South Dakota to recover benefits for the death of an insured society member who had been a citizen of South Dakota throughout the member’s membership. The benefits arose under the society’s constitution, which required that any action for such benefits could not be brought more than six months after the society’s executive committee disallowed a claim for benefits. The limitation period in the society’s constitution was valid under Ohio law. Wolfe’s claim was untimely under the society’s constitution, but it was timely under South Dakota’s general limitations provisions for contract claims. The South Dakota court declined to enforce the society’s limitation period and instead followed South Dakota law and allowed the claim to proceed. The society appealed and argued that full faith and credit required the South Dakota court to enforce the society’s limitation period.
Rule of Law
Issue
Holding and Reasoning (Burton, J.)
Dissent (Black, J.)
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