American Banana Co. v. United Fruit Co.
213 U.S. 347 (1909)

  • McConnell bought American Banana, which was a Columbian company operating on what is now Panama (but was then part of Columbia).
  • A competitor, United Fruit, threatened American Banana, and eventually had Costa Rican soldiers invade Panama and seize the American Banana plantation.
    • The plantation was eventually transferred in a Costa Rican court to United Fruit.
  • McConnell sued in US Court under the Sherman Anti-Trust Act.
    • United Fruit argued that the US did not have jurisdiction to hear the case.
  • Thee Trial Court dismissed the case.
    • The Trial Court found that US Courts did not have jurisdiction to hear the case, because the alleged acts didn't occur on US soil.
  • The US Supreme Court affirmed.
    • The US Supreme Court found that, in general, jurisdiction is territorial.
      • In this case, since the alleged acts occurred completely on Panamanian soil, it could only be tried in a Panamanian court.
    • McConnell argued that since he was a US citizen, US Courts had jurisdiction, but the Court disagreed.
      • "The acts causing the damage were done, so far as it appears, outside the jurisdiction of the US and within that of other States. It is surprising to hear it argued that they were governed by the Act of Congress."
  • This decision was a very narrow construction of the limits of jurisdiction. They were later expanded in United States v. Aluminum Co. of America (148 F.2d 416 (1945)), and Timberlane Lumber Co. v. Bank of America (549 F.2d 597 (1976)).