Texas & Pacific Railway Co. v. Mugg
Headline: Court enforces federal published freight rates, reversing a Texas ruling and holding consignees must pay the Interstate Commerce Commission’s schedule charges to recover interstate goods even if a lower rate was promised.
Holding:
- Consignees must pay published interstate schedule rates to recover freight, even if billed a lower rate.
- Carriers can hold goods until the schedule amount filed with the ICC is paid.
- State limits on bill-of-lading charges cannot override federal schedule requirements.
Summary
Background
A shipper sued a railroad after the carrier refused to deliver furniture that had been consigned to him. The bill of lading showed a rate of 69 cents per hundred pounds (charges $82.80), but the published interstate schedule in force was 84 cents (charges $100.80). The shipper did not know the billed rate was lower than the published schedule. The Alabama court had applied a similar holding in a related case, and this Court relied on Railroad Co. v. Hefley in deciding the present dispute.
Reasoning
The key question was whether a consignee could get the goods or damages by paying the amount named in the bill of lading when the federal published rate was higher. The Court held that federal law gives the carrier a lien for the published interstate schedule rate filed with and approved by the Interstate Commerce Commission. That lien stands even if the consignee paid or tendered the lower billed amount or was unaware of the difference. Under this rule, the carrier need only be paid the schedule amount to release the goods.
Real world impact
The decision means consignees who receive interstate shipments must pay the published ICC schedule charges to recover goods when the carrier insists on the schedule rate. State rules or lower billed rates cannot defeat the federal schedule lien. The Court reversed the Texas appellate judgment and sent the case back to that court to proceed consistent with this opinion.
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