Calveston, Harrisburg & San Antonio Railway Co. v. Woodbury

Background

Mrs. Woodbury bought a coupon ticket in Timmins, Ontario, to travel to El Paso, Texas, and checked a trunk that was lost while she traveled in Texas. She had not been told, and the record does not show, whether her ticket or the baggage check warned of any limit on the carrier’s liability. A jury awarded $500, but the railroad said a published tariff filed with the Interstate Commerce Commission limited baggage recovery to $100 unless a higher value was declared and an extra charge paid. The state trial court entered judgment for $100; the state court of appeals reversed to $500, and the case reached this Court on the amount of damages.

Reasoning

The Court held that the loss was a claim about property (baggage) and that the federal Act to Regulate Commerce applies to transportation to or from an adjacent foreign country like Canada. The Court accepted the Interstate Commerce Commission’s construction that the statute reaches carriers whose operations cross the border, so published tariffs govern baggage limits. Because the carrier had lawfully published a $100 limitation and Mrs. Woodbury did not declare a higher value or pay extra charges, the tariff bound both carrier and passenger and limited recovery to $100.

Real world impact

The decision treats baggage brought from nearby foreign points as governed by federal rail rules, so carriers may limit baggage liability by published tariff terms. Passengers who do not declare higher value and pay required excess charges cannot recover more than the published limit; the Court noted that the rule applies to baggage, not to claims for personal injury, which are governed differently.