## Facts

- The United States espoused a claim by Charles (or Edgar A.) Hatton, a U.S. national, under the 1923 General Claims Convention between the United States and Mexico.
- Hatton alleged that during the revolutionary disturbances in Chihuahua in 1913–1914, forces associated with General Julián Medina seized, consumed, or destroyed his cattle and horses and caused damage to ranch property and improvements.
- The claim included losses of livestock and asserted injury to ranch operations, with the claimant attributing the acts to forces said to be operating as part of (or aligned with) Mexican authorities.
- Mexico denied international responsibility on the ground that the wrongdoers were revolutionary forces not shown to be acting as agents of the constituted Government, and it challenged Hatton’s proof of ownership, causation, and valuation.
- The evidentiary record consisted largely of claimant-prepared statements and supporting affidavits, along with lists or inventories of alleged losses and valuation material submitted through the American Agency; Mexico filed a counter-memorial disputing both liability and the amount claimed.
- The Commission examined whether the proof connected the alleged seizures and destruction to forces for which Mexico was legally responsible, and whether the claimed amounts were established with sufficient certainty for an international award.

## Issues

1. Whether the alleged depredations by forces under or associated with General Julián Medina were attributable to Mexico for purposes of an international claim, either because the forces were acting on behalf of the constituted Government or because the Government later ratified the acts.
2. Whether Hatton proved, with adequate and specific evidence, that particular losses (livestock and ranch damage) were caused by identifiable forces and events for which Mexico bore responsibility.
3. Whether Hatton proved the existence, ownership, and value of the alleged losses with the degree of certainty required by the Commission to award compensation.

## Decision

- The Commission dismissed the claim in full.
- The Commission found that the record did not adequately show that the acts complained of were imputable to Mexico; general assertions about the status or allegiance of Medina’s forces were not enough to establish agency or governmental ratification.
- The Commission further held that, even if one assumed for argument that Medina could be treated as a governmental commander, the proof did not connect specific takings or destruction to specific troops, orders, or occurrences in a way that permitted a non-speculative finding of causation.
- On damages, the Commission concluded that the claimant’s valuation proof—resting heavily on ex parte lists and unsupported statements—did not establish the amount of loss with the required certainty; the Commission would not base an award on figures it regarded as conjectural.
- Given the thin and conflicting character of the proof and the lack of reliable corroboration subject to testing, the Commission held that an award would rest on guesswork and therefore could not be made.

## Legal Principles

- The claimant (through the espousing state) bears the burden to prove facts establishing both state responsibility and the amount of loss.
- For injuries caused by revolutionary or insurgent forces, international responsibility requires proof that the actors were agents of the constituted Government (or otherwise acted under its authority) or that the Government later ratified or adopted the conduct; broad statements of affiliation do not suffice.
- Proof of causation must link particular losses to particular acts and actors in a manner that allows the tribunal to make findings on a concrete record rather than inference piled on inference.
- International tribunals require a reasonable degree of certainty in proof of value and will reject claimed amounts grounded mainly on ex parte inventories, unsupported estimates, or materials not corroborated by contemporaneous records or reliable testimony.
- Where the evidence is vague, contradictory, or too incomplete to permit findings without speculation, the proper disposition is dismissal rather than a reduced award based on approximation.

## Conclusion

In Hatton, the General Claims Commission denied recovery for alleged revolutionary-era takings and destruction in Chihuahua because the United States did not prove that the acts were legally attributable to Mexico and did not establish the claimed losses and their value with sufficient certainty to support an international award.


Hatton (U.S.) v. United Mexican States, 4 R.I.A.A. 329 (Gen. Claims Comm’n (U.S.-Mex.) 1928).