St. Louis, Iron Mountain & Southern Ry. Co. v. McKnight - 244 U.S. 368 (1969)
U.S. Supreme Court
St. Louis, Iron Mountain & Southern Ry. Co. v. McKnight, 244 U.S. 368 (1917)
St. Louis, Iron Mountain & Southern
Railway Company v. McKnight
Argued May 2, 1917
Decided Junc 4, 1917
244 U.S. 368
Where a carrier, by reason of temporary and permanent injunctions against state officials and shippers and travelers as a class, collects rates in excess of those fixed by law, the right of a person, who did not appear, to sue for the excess paid by him during the restraint revives when the final decree is reversed by this Court and its mandate is issued to dismiss the bill.
Viewed from the standpoint of equitable jurisdiction, a class bill to restrain all such persons from suing to recover their overpayments is not maintainable as a bill to prevent multiplicity of suits in the absence of any controverted question of fact or law common to their claims.
In a suit to test the validity of rates fixed by the State of Arkansas, the district court, by injunction pendente lite and later by final decree, enjoined the enforcement of the rates and prohibited shippers and travelers generally from suing the carrier for its failure to keep them in effect. The decree having been reversed by this Court and mandate issued with directions to dismiss the bill, Allen v. St. Louis, Iron Mountain & Southern Ry. Co., 230 U. S. 553, held that thereafter the district court was without power to inquire into and assess the damages sustained by shippers or travelers by reason of the temporary and permanent injunctions, for the purpose of fixing liability on the temporary injunction bonds, at least as to persons who did not elect to appear and make claim, and that therefore a reference to that end could afford no basis for an ancillary suit to enjoin such persons from suing in the state court (after the dismissal of the original bill) to recover excess rates collected by the carrier under the temporary and permanent injunctions.
Rule 15 of the District Court for the Eastern District of Arkansas, quoted in a footnote to the opinion, infra 244 U. S. 373, relates merely to damages recoverable on bonds accompanying restraining orders or temporary injunctions.
Damages arising from the restraints of a permanent injunction, afterwards reversed, are not recoverable on temporary injunction bonds (Houghton v. Meyer, 208 U. S. 149), particularly where the decree of permanent injunction expressly released further liability on the bonds.
220 F. 876 affirmed.
The case is stated in the opinion.