Amos Kendall, Plaintiff in Error v. William B. Stokes, Lucius W. Stockton, and Daniel Moore, Survivors of Richard… (SCOTUS 1845)

Summary

The Court reversed a judgment awarding damages against a former postmaster general on two counts. It held that the plaintiffs could not pursue the original claims after submitting them to a statutory referee, receiving an award, and obtaining payment, and that a public officer was not liable for an error of judgment in a discretionary official act performed without malice. It also held that the plaintiffs' prior successful mandamus proceeding barred a later action seeking additional damages for the same refusal to enter the credit, and that much of the special-damages evidence was inadmissible.

Holding

Action based on suspension and recharge of credits after statutory reference and award. The plaintiffs could not maintain the action on the original claim after the matter had been referred, an award had been made, and the awarded amount had been received. Independently, Kendall was not liable for an error of judgment in suspending or reviewing the credits because he acted as a public officer in a discretionary official matter and without malice.

Effect of the prior mandamus proceeding on the later damages action. The plaintiffs' successful mandamus proceeding barred a subsequent action for damages based on the same refusal to enter the credit after they had obtained and received the benefit of the mandamus judgment.

Admissibility and scope of special damages. The evidence of special losses and litigation-related expenses was improperly admitted. The plaintiffs could not recover damages that had already been included in the solicitor's award, and the pleaded claim did not support recovery of the unestablished special damages.

Summary

Holding

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