## Facts

- An Army soldier was injured in a collision involving a motor truck allegedly operated negligently by Standard Oil’s driver.
- While the soldier was disabled, the United States paid for his hospitalization and continued paying his military wages.
- The United States sued the alleged tortfeasors to recover (1) hospital costs and (2) the soldier’s continued pay, framed as damages for “loss of the soldier’s services,” analogizing to a common-law master’s action for injury to a servant.
- The federal district court entered judgment for the United States.
- The Ninth Circuit reversed, concluding the United States lacked a cause of action.
- The Supreme Court granted certiorari.

## Issues

1. Whether the existence and scope of any right of the United States to recover for injury to a soldier is governed by state law or federal law.
2. If governed by federal law, whether courts may recognize, absent congressional authorization, a federal cause of action allowing the United States to recover a soldier’s pay and medical expenses from third-party tortfeasors.

## Decision

- The Supreme Court affirmed the Ninth Circuit.
- Federal law, not state law, governs legal incidents of the relationship between the United States and members of its armed forces.
- Nevertheless, absent legislation, the United States has no judicially created right to recover from a tortfeasor the soldier’s pay and medical expenses.
- The Court declined to create a new category of tort liability with broad fiscal and policy consequences, leaving the matter to Congress.

## Legal Principles

- The legal incidents and consequences of the U.S.–service member relationship are distinctively federal and are determined by federal authority rather than varying state rules.
- Federal courts should not create a new federal common-law cause of action allowing government reimbursement for benefits paid to injured service members without statutory authorization.
- Where recognizing a reimbursement right would require policy choices about scope and interaction with existing federal benefit schemes, such choices are for Congress, not the judiciary.
- There is no general inherent federal common-law right permitting the United States to recoup expenditures merely because they were triggered by a third party’s wrongful conduct.

## Conclusion

The Supreme Court held that federal law controls questions arising from the government’s relationship with its soldiers, but refused to recognize, without congressional action, any federal common-law claim enabling the United States to recover a soldier’s continued pay and medical expenses from private tortfeasors.


United States v. Standard Oil Co. of Cal., 332 U.S. 301 (1947)