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Vance v. W.A. Vandercook Co.
United States Supreme Court
170 U.S. 468, 18 S. Ct. 645, 42 L. Ed. 1111 (1898)
W. A. Vandercook Co. (Vandercook) (plaintiff), a California corporation, shipped 68 packages of wine from California to South Carolina. The wine was seized in South Carolina and came to be possessed by S. W. Vance (defendant), a citizen of South Carolina. Vandercook filed a lawsuit against Vance to recover the wine, which was worth $1,000, and sought special damages of $10,000. Because Vandercook alleged damages in excess of $2,000, which was the amount-in-controversy requirement for diversity jurisdiction, Vandercook filed the lawsuit in federal circuit court. Under South Carolina state law, special damages were only recoverable by a plaintiff seeking to recover property if the plaintiff received some direct injury. Vance moved to dismiss the case for lack of jurisdiction, arguing that Vandercook could not recover the special damages it alleged under South Carolina law and that, without those damages, Vandercook’s complaint did not meet the amount-in-controversy requirement for diversity jurisdiction. The circuit court found in favor of Vandercook. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (White, J.)
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