Wells, Fargo & Co. v. Neiman-Marcus Co.

Background

A person shipped a seven‑pound package of furs from New York to Dallas. The express company’s receipt said the carrier would not be liable for more than fifty dollars unless a different value was declared; no higher value was written. The consignor’s clerk filled out the receipt and handed the package to the carrier’s agent; the carrier’s tariff instructed agents to ask for a declared value, but that step was not performed. The actual furs were later proved to be worth $400, and a state court awarded the owner the full value after a jury waiver.

Reasoning

The core question was whether the owner could recover full value despite accepting a receipt that fixed the shipment value at $50 and obtained the lower rate. The Court held that the declared valuation set the basis for the rate and limited liability. The opinion explained that the owner, by accepting the receipt and the lower rate, was bound by the valuation used to calculate that rate, so recovery should not exceed the amount that served as the rate basis.

Real world impact

The decision reverses the lower court’s full‑value award and sends the case back for proceedings consistent with the rule that liability corresponds to the declared shipment value. It means owners who accept a low declared value and the lower rate may be limited to that amount if goods are lost. Shippers who want full recovery must declare higher value and pay the higher rate; carriers may rely on valuation clauses tied to published rates.