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United States v. Acme Operating Corp.

Citations: 288 U.S. 243; 53 S. Ct. 332; 77 L. Ed. 725; 1933 U.S. LEXIS 941Docket: 319

Court: Supreme Court of the United States; February 6, 1933; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The Supreme Court case, United States v. Acme Operating Corporation, addressed the issue of just compensation for the requisition of two steamships chartered by Acme Operating Corporation and mortgaged to the Fidelity Trust Company. The vessels were requisitioned by the Shipping Board under the Act of June 15, 1917, and a contract stipulated that the government could deduct its expenses from any compensation due. The Court of Claims initially dismissed Acme's petition but ruled in favor of the Liberty Trust Company, the intervener, as the assignee of the mortgage. The central legal question was whether the Court of Claims correctly prioritized the intervener's claim over the government's lien. The court decided that the government’s lien for unpaid transportation charges was superior to the mortgagee's claim, precluding a monetary judgment for the intervener. Although the intervener was allowed to recover repair costs, the court found no basis for additional claims based on construction liens, which were not raised or addressed in lower court proceedings. Ultimately, the decision reversed the lower court's ruling, affirming the government's priority over mortgage claims.

Legal Issues Addressed

Just Compensation under the Act of June 15, 1917

Application: The Supreme Court examined whether the compensation due for requisitioned vessels should account for government expenses and debts owed to the mortgagee.

Reasoning: The case arose after the Shipping Board requisitioned the vessels under the Act of June 15, 1917, while they were undergoing repairs.

Mortgagee’s Entitlement to Compensation

Application: The court determined that the mortgagee was not entitled to compensation for requisitioned ships due to superior government claims and liens.

Reasoning: The court ruled that the mortgagee was not entitled to compensation for the requisitioned ships, as they were under the custody of the admiralty court.

Priority of Government Liens

Application: The court upheld that government liens for unpaid balances on requisitioned vessels take precedence over mortgage liens.

Reasoning: Additionally, it allowed the government to apply any excess compensation to the mortgage debts and established government liens on the vessels for unpaid balances, superior to existing mortgage liens.

Reimbursement for Repair Costs

Application: The court allowed the intervener to recover costs for vessel repairs, considering these as damages to secured property.

Reasoning: However, it allowed the intervener to recover $129,297.66 spent on repairing the vessels, arguing that damage to the vessels constituted injury to the secured property.

Validity of Construction Liens

Application: The court did not address the validity of construction liens as they were not included in the petition or lower court considerations.

Reasoning: These construction lien claims were not included in the intervener's petition or considered by the lower court.