Vishipco Line v. Chase Manhattan Bank

The Chase Manhattan Bank (Chase) (defendant) was a New York-based bank. Chase maintained a branch office in Saigon until April 24, 1975, when Chase abandoned Saigon due to its imminent fall to communist rule. Chase closed the Saigon branch without providing notice to depositors. Saigon fell to the communists on April 30. On May 1, Saigon’s new government announced the confiscation of, among other things, all banks. Vishipco Line and nine other maritime corporations (collectively, Vishipco) (plaintiffs) maintained South Vietnamese piastre-denominated demand deposit accounts at Chase’s Saigon’s branch. After Chase closed its Saigon branch, Vishipco asked Chase to pay the amounts that were its Saigon accounts in New York in United States dollars. When Chase refused, Vishipco sued Chase for breach of contract in federal district court pursuant to the court’s diversity jurisdiction. The district court dismissed Vishipco’s complaint. Vishipco appealed. Chase responded that it was not obliged to pay Vishipco because, among other things, (1) the new government seized Vishipco’s accounts, and the act-of-state doctrine barred Vishipco from challenging the seizures; (2) local conditions made it impossible for Chase to pay Vishipco in Vietnam; and (3) the federal judgment-day rule required that any judgment be converted to dollars as of the judgment date; however, piastres, which had value when Chase closed its Saigon branch, now were worthless.