Central Trust Company v. Central Trust Company of Illinois/Opinion of the Court
The management of the great postoffice business of the country is placed in the hands of the Postmaster General and assistants. Rev. Stat. §§ 388, 389, 396, U.S.C.omp. Stat. 1901, pp. 218, 224. In the discharge of his duties as Postmaster General, he has assigned to the First Assistant Postmaster General 'the preparation of decisions as to delivery of ordinary mail, the ownership of which is in dispute.' Postal Laws and Regulations, 1902, § 17, ¶9. The question here presented is whether, the First Assistant Postmaster General having directed the postmaster at Chicago to deliver to the 'Central Trust Company of Illinois,' defendant herein, mail matter addressed 'Central Trust Company, Chicago, Ill.,' without any further designation of the party for whom it was intended, the courts are, upon the facts as presented, justified in setting aside that order and directing the delivery of such mail to the complainant. It is not always easy to determine for whom a letter is intended. In furtherance of the effort to secure delivery of mail matter to the proper party, &Par;3 and 4, § 634, and &Par;4 and 5, § 645, of Postal Laws and Regulations, provide:

'Sec. 634, par. 3. When a postmaster is in doubt as to the identity of the addressee, he may require proof, and should exercise great care, especially where mail matter appears to be of value, to make proper delivery.

'Par. 4. Where two or more persons of the same name receive mail at the same office, the postmaster should advise them to adopt some address or means by which their mail may be distinguished. Postmasters will deliver such matter according to their best judgment, and will not return it to the mailing office for better description of the addressee until, after inquiry, they are unable to determine to whom it should be delivered.' 'Sec. 645, par. 4. Attempts to secure the mail of an established house, firm, or corporation through the adoption of a similar name should not be recognized. Where disputes arise between individuals, firms, or corporations as to the use of a name or designation, matter addressed to a street, number, or building should be delivered according cording to such address. When not so addressed, the mail will be delivered to the firm or corporation which first adopted the name of the address at that place.

'Par. 5. When in doubt as to the firm or corporation for which any mail matter is intended, and claim therefor is disputed, postmasters will withhold delivery, and report the facts and any statements made by either claimant to the First Assistant Postmaster General, for advice.'

Appellant contends that its legal name is 'Central Trust Company' while the legal name of defendant is 'Central Trust Company of Illinois;' that therefore it has a right to have mail directed to 'Central Trust Company, Chicago,' without further designation, delivered to it rather than to defendant. The argument primarily is that every corporation is entitled to the legal benefit of its own name; that when that name appears on mail matter as the party addressed, and nothing else is shown, the postmaster has simply the ministerial duty of making a delivery to that corporation, and that a failure to discharge this ministerial duty can be corrected by the courts.

While in a certain sense it is true that the benefit of one's legal name belongs to every party, individual or corporation, yet that may not be the name by which it is customarily known or addressed, and of course the object is and must be to deliver the mail matter to the party for whom it is intended. In the determination of this it may often be necessary to look beyond the exact legal name. Many things may have to be considered, and the action of an officer charged with that duty should not lightly be disturbed by the courts, and only when it is clear that a mistake has been made or a wrong done. Initials are often used, abbreviations made, words left out. The number of letters delivered to the respective parties and the disposition made by each of those received may cast some light upon the question, for while a party for whom a single letter is intended has a right to receive it, yet the number of letters, taken in connection with the amount of business apparently done by the recipient, may well suggest for whom any given letter was intended, and the action taken by the recipient, when, as here, each knows of the existence of the other, may show its good or bad faith in dealing with the postoffice. So, also, the character of the business done may be considered. Where a corporation is engaged in the banking business, letters from other banks will point to it as the intended recipient, while, if it is a real estate corporation, letters from real estate firms will indicate differently. And so we might go on and mention other things which, while by not means conclusive, tend to throw light on the matter.

We have had occasion to consider the effect of findings of fact by officers in charge of the several departments of government, and the accepted rule is that those findings are conclusive unless palpable error appears. Bates & G. Co. v. Payne, 194 U.S. 106, 48 L. ed. 894, 24 Sup. Ct. Rep. 595, and cases cited in the opinion; United States ex rel. Parish v. MacVeagh, 214 U.S. 124-131, 53 L. ed. 936-938, 29 Sup. Ct. Rep. 556. In National L. Ins. Co. v. National L. Ins. Co. 209 U.S. 317, 52 L. ed. 808, 28 Sup. Ct. Rep. 541, it appeared that the Postoffice Department had made a special order in reference to the delivery of mail, and the court was asked to correct that order. In denying this application, the court, by Mr. Justice Peckham, said (p. 325):

'The appeal made by the complainant to the Department was really nothing but an appeal to its discretion. . . . Assuming that the court in some cases has the power to, in effect, review the determination of the Department, we do not think this is an occasion for its exercise. The complaint is really appealing from the discretion of the Department to the discretion of the court, and the complainant has no clear legal right to obtain the order sought. See Bates & G. Co. v. Payne, 194 U.S. 106-108, 48 L. ed. 894, 895, 24 Sup. Ct. Rep. 595.

'A court in such case ought not to interfere in the administration of a great department like that of the Postoffice by an injunction, which directs the Department how to conduct the business thereof, where the party asking for the injunction has no clear right to it.'

We do not deem it necessary to consider other questions discussed by counsel, for, upon the facts presented and for the reasons stated, we are of opinion that there is not enough to show such clear right in the complainant as justifies the setting aside of the order of the First Assistant Postmaster General.

The decree is therefore affirmed. 

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