Western Union Telegraph Co. v. Brown
United States Supreme Court
234 U.S. 542, 34 S. Ct. 955, 58 L. Ed. 1457 (1914)
- Written by Steven Pacht, JD
Facts
While in Washington, D.C., Brown (plaintiff) was sent a telegraph from South Carolina imploring Brown to travel to South Carolina immediately due to the death of his sister. The telegraph was to be delivered by Western Union Telegraph Co. (Western Union) (defendant). Although the telegraph arrived in Washington, Western Union allegedly negligently failed to deliver it to Brown, and Brown missed his sister’s funeral. Brown sued Western Union in South Carolina state court pursuant to a South Carolina statute, alleging that Western Union’s negligence had caused him to suffer mental anguish. At trial, the court instructed the jury to consider Western Union’s alleged negligence in Washington in accordance with South Carolina law. The jury awarded Brown $750 in damages. The South Carolina Supreme Court affirmed. Western Union appealed.
Rule of Law
Issue
Holding and Reasoning (Holmes, J.)
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