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Keywords

plaintiffjurisdictionverdictmotioncorporationwrit of mandamus
plaintiffverdictcorporation

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In re Skinner & Eddy Corporation, 265 U.S. 86, 44 S.Ct. 446, 68 L.Ed. 912

Facts

On June 15, 1921, Skinner & Eddy Corporation filed a suit against the United States in the Court of Claims for over $17 million, based on alleged balances due for ship construction and related claims. After a lengthy period of inactivity, the petitioner moved to dismiss the suit without prejudice on April 11, 1923, citing jurisdictional issues. The Court of Claims granted this motion, but the government later sought to vacate the dismissal and file a counterclaim, leading to the current petition for mandamus.

On June 15, 1921, the petitioner brought this suit against the United States in the Court of Claims for $17,493,488.97. The cause of action was based on balances alleged to be due for the construction of certain ships, for bonuses for advanced deliveries of others, and for extra labor, extra work and repairs on other vessels, all for the United States.

Issue

Whether the Court of Claims had the authority to vacate its prior order of dismissal and allow the government to file a counterclaim after the petitioner had moved to dismiss the case without prejudice.

Whether the Court of Claims had the authority to vacate its prior order of dismissal and allow the government to file a counterclaim after the petitioner had moved to dismiss the case without prejudice.

Rule

A plaintiff has an absolute right to discontinue or dismiss their suit at any stage of the proceedings prior to verdict or judgment, and this right is substantial and not dependent on the reasons provided for the dismissal.

A plaintiff has an absolute right to discontinue or dismiss his suit at any stage of the proceedings prior to verdict or judgment, and this right has been declared to be substantial.

Analysis

The court applied the rule that a plaintiff's right to dismiss a case without prejudice is absolute, regardless of the reasons given. It noted that the government had not taken any significant action that would justify a claim of prejudice from the dismissal. The court emphasized that the jurisdiction of the Court of Claims could not be resumed retroactively after the dismissal, especially in light of the petitioner's subsequent state court action.

The court applied the rule that a plaintiff's right to dismiss a case without prejudice is absolute, regardless of the reasons given. It noted that the government had not taken any significant action that would justify a claim of prejudice from the dismissal.

Conclusion

The court granted the writ of mandamus, restoring the order of dismissal and prohibiting the Court of Claims from exercising further jurisdiction over the case.

Writ absolute.

Who won?

Skinner & Eddy Corporation prevailed in the case because the court upheld their right to dismiss the suit without prejudice, affirming that the government had not established any grounds for prejudice.

Skinner & Eddy Corporation prevailed in the case because the court upheld their right to dismiss the suit without prejudice.

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