William Danzer & Co. v. Gulf & Ship Island Railroad

Background

A lumber company shipped a carload of lath in 1917 that was misrouted, causing loss. The buyer received the bill of lading and later sought money from the carrier. The shipper filed a complaint with the Interstate Commerce Commission in 1921, after the two-year deadline for such claims had passed. The Commission awarded about $307 in 1922, the carrier did not pay, and the shipper sued in 1923. The carrier argued the Commission’s revival of the expired claim was unlawful and unconstitutional.

Reasoning

The Court addressed whether a new provision in the Transportation Act could be read to revive claims already barred by the statute of limitations. The Court explained that when time limits destroy a carrier’s liability, they do more than limit remedies — they define the right itself. The opinion relied on earlier decisions saying lapse of time can extinguish liability, distinguished older cases where repeal only affected remedies, and concluded the Act’s provision would not be construed retroactively to create new liability. Applying it retroactively, the Court said, would deprive the carrier of property without due process under the Fifth Amendment.

Real world impact

The ruling leaves carriers free from suits that were already extinguished before the Transportation Act took effect. Shippers whose claims expired before the Act cannot use the new provision to restart those claims. The judgment for the carrier was therefore affirmed, and the Commission’s order could not be enforced against the railroad.