Pittsburgh, Cincinnati, Chicago & St. Louis Railway Co. v. Fink

Background

A railroad company sued a consignee, a man named Fink, to recover fifteen dollars for freight on two boxes of Indian relics shipped from Los Angeles to Dayton. The waybill showed charges of fifteen dollars and Fink paid that amount when the goods were delivered, but the company’s filed interstate tariff required thirty dollars. The case moved through local courts with mixed results before reaching this Court on writ of error from the Court of Appeals of Montgomery County, Ohio.

Reasoning

The Court addressed whether the consignee could avoid paying the legally filed tariff rate after accepting interstate goods. Citing the statute then in force, the Court explained carriers may charge only the rates filed with the Interstate Commerce Commission and may not lawfully accept less. Because the carrier’s right to the legally filed rate is protected and the carrier had a lien on the goods for that charge, the consignee who accepted the shipment must pay the statutory rate. The Court rejected arguments that private agreements about ownership or the carrier’s lack of knowledge of those agreements relieved the consignee, and held that estoppel cannot be used to defeat the statute’s uniform-rate requirement.

Real world impact

The decision enforces uniform, filed freight rates for interstate shipments and allows carriers to recover unpaid tariff differences from consignees who accept goods. The ruling favors consistent enforcement of published tariffs over individual hardships and sends the case back to the lower court for further proceedings consistent with this opinion.