Sutcliffe Storage & Warehouse Co. v. United States

On April 13, 1942, Sutcliffe Storage & Warehouse Co. (plaintiff) executed a lease of certain property to the United States Navy that was effective until June 30, 1943. The original lease was subsequently renewed by three renewal leases. Each renewal lease was for a period identical to that of the original lease. On June 15, 1942, the Navy allegedly began to occupy and use additional premises that were not included in the leases. In February 1946, Sutcliffe brought four actions against the United States (defendant) in the United States District Court for the District of Massachusetts seeking damages for the Navy’s occupancy and use of the additional premises. Each action claimed damages of less than $10,000, and covered a period corresponding to one of the leases, with the first action covering the period from June 15, 1942 to June 30, 1943. The district court granted the United States’ motions to dismiss the three actions covering the periods that corresponded to the renewal leases, on the grounds that they were brought for inseparable parts of the claim in the first action. Sutcliffe appealed, arguing that the general rule against splitting causes of action does not apply here because if it is precluded from trying these actions separately, it will be forced to bring suit in the Court of Claims in Washington under 28 U.S.C.A. § 41(20), because its claims will aggregate to more than $10,000.