American Railway Express Co. v. Daniel
Headline: Ruling lets an express company limit its liability to the value listed on its receipt, reversing a state court and holding published rate schedules binding so shippers bear declared-value choices.
Holding: The Court reversed and held that the carrier was entitled to have its published rate schedules admitted and that shippers are bound by the declared value on the receipt, so the carrier’s liability was fixed at the stated amount.
- Holds shippers responsible for the declared value shown on shipment receipts.
- Allows carriers to use published rate schedules as binding evidence in disputes.
- Limits a shipper’s recovery to the receipt’s stated value when lower rates were chosen.
Summary
Background
A person who sent a parcel sued an express company after the parcel was not delivered. The company admitted it owed fifty dollars because that value was written on the receipt, but the sender sought more. After a conversation between the sender’s agent and the company’s agent, fifty dollars was written on the receipt, and the sender later received the receipt. The rate for goods valued over fifty dollars was higher, and the company offered its filed rate schedules as proof, but those schedules were excluded at trial. A jury awarded the sender one hundred dollars, and the State Supreme Court affirmed by an evenly divided court.
Reasoning
The central question was whether the company could be held for more than the value stated on its receipt and whether its published rate schedules should be treated as evidence that binds both sides. The Court said the company’s knowledge about the agent’s ignorance did not matter because the company acted in good faith. The schedules filed with the Interstate Commerce Commission should have been admitted and would show how values and rates related. The Court therefore concluded the sender was bound by the value on the receipt and reversed the state court judgment.
Real world impact
The decision means senders who accept a carrier’s receipt are treated as bound by the declared value, and carriers may rely on their published rate schedules in disputes. Because the Court reversed the judgment, the lower-court award for the sender does not stand and the carrier’s liability is limited by the receipt’s stated amount.
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