Shankland v. Washington


Shankland v. Washington,, is a United States Supreme Court case on lotteries and contractual relations, which held that when individuals purchase a share of someone else's contractual right to a future payout, they do not enter into a contractual relationship with the original seller.

Background

After Congress chartered a National Lottery in Washington, D.C., the city sold all tickets to a man named Gillespie. Gillespie sold half-tickets redeemable for half of the associated ticket's value upon the city's drawing. When Alexander B. Shankland was unable to redeem his half-ticket for its $25,000 value through Gillespie, he sought his payout from the city government. The city government countered that it had already fulfilled its contractual obligations by paying Gillespie the full amount, prompting this lawsuit.

Supreme Court

In a unanimous opinion written by Associate Justice Joseph Story, the Supreme Court held that when individuals purchase a share of someone else's contractual right to a future payout, they do not enter into a contractual relationship with the original seller.
Story's claim that "the general rule of law is, that a delegated authority cannot be delegated" has been cited to support the nondelegation doctrine, despite this case dealing with a city government's transactions with private individuals.