Cincinnati, New Orleans & Texas Pacific Railway Co. v. Rankin
Headline: Signed shipping receipt upholds carrier’s $75-per-mule liability limit, reversing a state-court award of full value after a wreck and requiring shippers to prove otherwise.
Holding: The Court held that a signed bill of lading stating lawful alternate rates and valuations is prima facie evidence of the shipper’s choice, so the carrier’s stated limit on recovery applies unless the shipper proves otherwise.
- Allows carriers to enforce signed shipping receipts that limit liability to stated values.
- Shifts burden to shippers to prove limits were not lawfully offered or agreed.
- Makes it harder to recover full market value without evidence contradicting the bill of lading.
Summary
Background
Experienced shippers delivered a car of mules to a railroad at Danville, Kentucky, for transport to Atlanta, Georgia, and accepted a bill of lading (the written shipping receipt). That receipt stated horses or mules were valued at $75 each for the reduced rate. After a wreck in Tennessee some animals died or were injured and the shippers sued for full value of $250 per animal. At trial the railroad did not produce its filed rate schedules, and the state courts allowed the shippers to recover full value, finding the limitation ineffective.
Reasoning
The main question was whether the signed bill of lading’s plain statements about published rates and valuations could limit the railroad’s liability. The Court said those clear recitals are prima facie admissions by the shipper and give the carrier a presumption of lawful conduct in interstate shipments. While a carrier may need to prove filed rates in some cases, a bill of lading signed by both parties ordinarily shows the shipper’s choice of the limited rate and valuation, and the shipper bears the burden to contradict those admissions. The Court therefore reversed the state-court judgment that awarded full value.
Real world impact
The ruling means that for interstate shipments a signed shipping receipt that plainly offers alternate rates and valuations can prevent full recovery unless the shipper proves the limitation was not lawfully offered or accepted. The case was sent back to the Tennessee courts for further proceedings consistent with this view.
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