Hughes v. United Van Lines, Inc.

Background

A case from the Seventh Circuit involved a shipper seeking money from a carrier after goods were damaged in interstate transport. The Seventh Circuit concluded that the Carmack Amendment, a federal law governing interstate shipments, prevents shippers from suing under state law or common-law claims for such damage. That court said the federal law was meant to create uniform rules about carrier liability and cited earlier Supreme Court and circuit decisions supporting that view.

Reasoning

The key question was whether the federal Carmack rule displaces state-law remedies for lost or damaged interstate cargo. The Seventh Circuit answered yes, relying on the view that Congress intended uniform federal guidance and on past cases interpreting the statute. Some other federal appeals courts agreed, while the Tenth Circuit and others reached the opposite conclusion, saying state remedies can still be used. The Supreme Court declined to review the case, so it did not resolve the disagreement.

Real world impact

Because the Supreme Court refused review, the Seventh Circuit’s ruling stands in that region and similarly decided circuits, limiting shippers there to federal remedies. The disagreement among appeals courts remains in place across the country, so shippers’ rights can vary by region. This denial is not a final nationwide decision on the statute and could be revisited if the Court takes a future case.

Dissents or concurrances

Justice White dissented from the denial, saying the split among the federal appeals courts warranted the Supreme Court’s review to settle whether the Carmack rule precludes state-law damage claims.