Two cases, decided by the Supreme Court of the United States on March 1O, 1913, may be considered together. They are developments of the cases reviewed in 11 MICH. L. Rev. 460. Plaintiff shipped two boxes and a barrel of "household goods" under an agreement that the goods, in case of loss, should be valued at $5 per hundred-weight. One box, weighing not over 200 pounds and actually worth $75, was lost. The Supreme Court of Arkansas affirmed a judgment against the carrier for the full value. 91 Ark. 97, 121 S. W. 932, 134 A. S. R. 56. On error the Supreme Court of the United States reversed and remanded the case for further proceedings. Kansas City Southern Ry. Co. v. Carl, 33 Sup. Ct. 391. In the other case the plaintiff shipped four bulls and thirteen cows, "show cattle," worth $10,640. The 'finding of the "Texas Court of Civil Appeals, 128 6. W. 932, was reversed on the ground that the recovery should have been limited to $30 for each bull and $20 for each cow, in accordance with the bill of lading. Missouri, Kansas & Texas Ry. Co. v. Harriman Bros., 33 Sup. Ct. 397.
Goddard, Edwin C. "The Effect of the Carmack Amendment to the Hepburn Act Upon Limitation by Common Carriers of the Amount of their Liability." Mich. L. Rev. 11 (1913): 588-91.