Crawford v. Hubbell
Headline: Decision allows express carriers to require shippers to pay or provide War Revenue Act stamps, letting carriers shift stamp expense onto customers and raising out-of-pocket shipping costs for senders.
Holding:
- Allows carriers to require shippers to pay or provide required war revenue stamps.
- Makes shippers bear additional out-of-pocket shipping costs.
- Affirms carriers can add stamp expense on top of existing rates.
Summary
Background
A shipper sued an express company after the company refused to accept packages unless the shipper paid for or provided a war revenue stamp required by the War Revenue Act of June 13, 1898. The company had set new rates after July 1, 1898, that added the stamp cost on top of its usual charges. A federal trial court dismissed the shipper’s complaint, and the Circuit Court of Appeals certified two legal questions to the Supreme Court about who must bear the stamp cost.
Reasoning
The Supreme Court referred to its opinion in a related case decided the same day and said the first certified question need not be answered here. Relying on the companion opinion’s reasoning, the Court answered the second question in the negative. In plain terms, the Court held that the statute does not bar an express carrier from shifting the expense of affixing and canceling the required stamp onto the shipper.
Real world impact
This ruling means express companies can require shippers to provide or pay for the War Revenue Act stamp in addition to regular transportation charges. The decision directly affects shippers who must now expect the added stamp cost when using express services. Because the Court declined to decide the first question here and relied on a companion opinion, the full allocation of tax responsibility was addressed through that related opinion rather than newly answered in this case.
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