Missouri, Kansas & Texas Railway Co. v. Harriman

Background

A Missouri shipper hired a railroad under a special live‑stock contract to move 17 cattle from Missouri to Oklahoma. The train derailed in Missouri and all animals were killed. The shipper sued in Texas state court and recovered full value; the case reached the Court to decide whether contract terms limiting recovery per head and requiring suits within ninety days were valid for interstate shipments.

Reasoning

The Court examined whether the contract’s declared per-head valuations ($30 per bull, $20 per cow) and the ninety‑day suit clause could stand under the federal statute governing interstate carriers and federal common law. Relying on prior federal decisions, the Court held such valuation clauses are enforceable when they form the basis for a lower freight rate and are not arbitrary, and that short suit deadlines in bills of lading are permissible if not unreasonably short. The Court therefore concluded the state courts erred in treating those stipulations as void and reversed the judgment for the shipper.

Real world impact

The decision lets rail carriers enforce declared valuation limits and short filing deadlines in interstate livestock contracts when those terms were part of a filed rate choice. Practically, shippers who accept a lower rate based on declared valuation cannot later recover a larger value, and must bring suit within agreed short periods. The ruling resolves the dispute under federal law rather than state rules.

Dissents or concurrances

One Justice dissented (Justice Pitney) and another Justice concurred in the result (Justice Hughes), showing some disagreement over the outcome.