Note and Comment

Authors

Edwin C. Goddard, University of Michigan Law School
Jack M. Hendrick, University of Michigan Law School
Wilson W. Mills, University of Michigan Law School
Samuel H. Morris, University of Michigan Law School
George A. Cram, University of Michigan Law School

Abstract

The Effect of the Carmack Amendment to the Hepburn Act Upon State Laws as to Limitation by Contract of the Amount of the Liability of a Common Carrier - Three recent decisions of the Supreme Court of the United States involving the construction, of the Carmack Amendment to the Hepburn Act may be considered together, as the second was governed wholly and the third largely by the decision of the first. In the first case plaintiff delivered to defendant express company at Cincinnati, Ohio, a diamond, ring consigned to Augusta, Georgia. The package was never delivered, and plaintiff recovered judgment in a Circuit Court in the state of Kentucky for $137.52. Defendant thereupon sued out a writ of error to the United States Supreme Court. Adams Express Company v. Croninger, 226 U. S. 491, 33 Sup. Ct. 148, decided January 6, 1913. In the second case horses were shipped under a bill of lading limiting recovery to $100 for each horse. Plaintiff in the United States Circuit Court of Appeals was given judgment for $3024.38 for the loss of a mare and colt. Latta v. Chicago St. P. M. & 0. Ry. Co., 172 Fed. 850, 97 C. C. A. 198, 184 Fed. 987, 106 C. C. A. 664- The case was appealed and decided by the United States Supreme Court in Chicago St. P. M. & 0. R. v. Latta, 226 U. S. 513, 33 Sup.

Recommended Citation

Edwin C. Goddard, Jack M. Hendrick, Wilson W. Mills, Samuel H. Morris & George A. Cram, Note and Comment, 11 Mich. L. Rev. 460 (1913).
Available at: https://repository.law.umich.edu/mlr/vol11/iss6/3