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Order of United Commercial Travelers of America v. Wolfe, 331 U.S. 586, 67 S.Ct. 1355, 91 L.Ed. 1687, 173 A.L.R. 1107, 36 O.O. 129

Facts

Edward C. Wolfe brought an action against The Order of United Commercial Travelers of America to recover benefits from a fraternal benefit certificate following the death of a member, Ford Shane. Shane had been a member of the society, which was incorporated in Ohio, and the society's constitution included a provision that claims must be filed within six months of disallowance. After Shane's death in 1931, his beneficiary filed a claim that was disallowed, and subsequent legal actions ensued, culminating in Wolfe's claim in 1934. The society argued that the claim was barred by the six-month limitation in its constitution.

The decedent, on July 31, 1920, applied for membership in the society through Rapid City Council No. 516, in Rapid City, South Dakota. He named his wife as his beneficiary in case of his death from accidental means. On May 8, 1931, he visited a physician's office in Rapid City, South Dakota, to be examined for stricture. The doctor applied a local anesthetic… In accordance with the procedure prescribed in the constitution of the society, the decedent's beneficiary promptly mailed to the society a notice of her son's death.

Issue

Whether the full faith and credit clause of the Constitution required South Dakota to enforce the six-month limitation period for filing claims as stipulated in the constitution of the fraternal benefit society incorporated in Ohio.

The case presents the question whether the full faith and credit clause of the Constitution of the United States required the court of the forum, South Dakota, to give effect to a provision of the constitution of the society prohibiting the bringing of an action on such a claim more than six months after the disallowance of the claim by the Supreme Executive Committee of the society.

Rule

The full faith and credit clause of the Constitution mandates that states must recognize and enforce the public acts, records, and judicial proceedings of other states, including the laws governing fraternal benefit societies.

We hold that, under such circumstances, South Dakota, as the state of the forum, was required, by the Constitution of the United States, to give full faith and credit to the public acts of Ohio under which the fraternal benefit society was incorporated, and that the claimant was bound by the six-month limitation upon bringing suit to recover death benefits based upon membership rights of a decedent under the constitution of the society.

Analysis

The Court analyzed the relationship between the member and the fraternal benefit society, emphasizing that the rights and obligations of members are governed by the laws of the state of incorporation, Ohio, and that the limitation period was valid under Ohio law. The Court concluded that South Dakota, as the forum state, was required to enforce the limitation period despite its own laws that generally allowed longer periods for contract actions.

The Court analyzed the relationship between the member and the fraternal benefit society, emphasizing that the rights and obligations of members are governed by the laws of the state of incorporation, Ohio, and that the limitation period was valid under Ohio law.

Conclusion

The Supreme Court reversed the judgment of the South Dakota Supreme Court, holding that the claimant was bound by the six-month limitation period in the society's constitution, and thus the society was not liable for the claim.

The Supreme Court reversed the judgment of the South Dakota Supreme Court, holding that the claimant was bound by the six-month limitation period in the society's constitution.

Who won?

The Order of United Commercial Travelers of America prevailed in the case because the Supreme Court found that the six-month limitation in the society's constitution was enforceable under the full faith and credit clause.

The Order of United Commercial Travelers of America prevailed in the case because the Supreme Court found that the six-month limitation in the society's constitution was enforceable under the full faith and credit clause.

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