Davis v. Cornwell
Headline: Court blocks shippers from enforcing a station agent’s promise to deliver freight cars on a set day, ruling such special contracts conflict with published tariffs and are not legally enforceable.
Holding: The Court held that an express promise by a station agent to furnish railcars on a particular day is invalid and unenforceable when it is not authorized by the carrier’s published tariffs.
- Prevents shippers from enforcing station-agent promises for guaranteed car delivery on a specific day.
- Requires carriers to follow published tariffs and avoid special advantages for individual shippers.
- Limits recovery when a carrier’s agent promises specific-day delivery not found in the tariff.
Summary
Background
A cattle shipper named Corn-well asked a station agent to have empty railcars ready on October 2, 1918, to load cattle for interstate transport. When the cars were not supplied, Corn-well sued Davis, the federal official designated under the Transportation Act, 1920, in a Montana state court for breach of an express promise to furnish the cars. The trial jury found for the shipper, and the state’s highest court affirmed that verdict before the case reached the Court.
Reasoning
The Court asked whether an express promise by an agent to provide cars on a particular day is valid under the Interstate Commerce Act and the carrier’s published tariffs. The Court explained that common carrier service is governed by published tariffs that imply a duty to use diligence to supply cars after reasonable notice. A special promise to furnish cars on a fixed day creates an extra obligation and gives a particular shipper a preference, which published tariffs prohibit. Citing earlier decisions, the Court held such special contracts are illegal when not authorized by the tariff, and therefore the promise was not enforceable.
Real world impact
The ruling means shippers cannot rely on informal promises from station agents to guarantee car delivery on a specific day unless the carrier’s published tariff allows it. Carriers must follow their published rates and rules to ensure equal treatment of shippers. Because the Court reversed the state judgment, the shipper’s recovery for the broken promise was denied, and similar lawsuits will face the same legal obstacle.
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