Fischer v. Monarch Van Lines, L.L.C.

2024 Ohio 2812
CourtOhio Court of Appeals
DecidedJuly 25, 2024
Docket113465
StatusPublished

This text of 2024 Ohio 2812 (Fischer v. Monarch Van Lines, L.L.C.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fischer v. Monarch Van Lines, L.L.C., 2024 Ohio 2812 (Ohio Ct. App. 2024).

Opinion

[Cite as Fischer v. Monarch Van Lines, L.L.C., 2024-Ohio-2812.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF OHIO

KILLIAN FISCHER, ET AL., :

Plaintiffs-Appellants, : No. 113465

v. :

MONARCH VAN LINES, LLC, : ET AL., : Defendants-Appellees.

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: July 25, 2024

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-22-964432

Appearances:

Cavell Law, LLC, and Hunter G. Cavell, for appellants.

Gabriela Orta, pro se.

SEAN C. GALLAGHER, J.:

Killian and Theresa Fischer appeal the trial court’s decision

dismissing their case for the lack of personal jurisdiction over Monarch Van Lines,

LLC, and Gabriela Orta, both of whom are residents of Austin, Texas. Orta filed a motion to dismiss for the lack of personal jurisdiction, but the defendants otherwise

have not defended in this action. For the following reasons, we nonetheless affirm.

The Fischers asserted three state law claims in the complaint: breach

of contract, unjust enrichment, and a violation of the Consumer Sales Practices Act

(“CSPA”) for the unworkmanlike services rendered under the terms of the contract.

They expressly sought in excess of $25,000 based on the breach-of-contract count,

$9,293.75 based on the unjust-enrichment count, and $91,760 on the CSPA count,

including the statutory trebling of damages. This case, however, is more

complicated than the pleading lets on because of the subject matter of the underlying

claims — implicating an interstate shipping agreement and claims against an

interstate carrier moving household goods. For this reason, the foundational law

not relevant to the disposition will be included while exploring the facts for the sake

of clarity.

According to the allegations in the complaint, Killian entered into a

contract with Monarch for the purpose of moving household goods from Texas to

Brecksville, Ohio. Monarch is alleged to have been the interstate carrier contracted

to pack, store, and ship the household goods. At the time they entered the contract,

the Fischers were also residents of Texas. The Fischers jointly alleged that Orta was

personally liable for the contract because she signed the agreement as a

representative of Monarch. But see Perk v. Tomorrows Home Solutions, L.L.C.,

2016-Ohio-7784, ¶ 10 (8th Dist.) (in general, the representative of a corporation is

not personally liable for a contract). There are no allegations that Orta was involved with the actual work performed or that she personally directed the employees or

agents to act in the manner that resulted in the damage to the Fischers’ property.

See Burns v. Spitzer Mgt., 2010-Ohio-5369, ¶ 32 (8th Dist.) (officer of a corporation

is only individually liable under the CPSA for conduct the officer actually undertook

or expressly directed to be done). The sole allegation implicating Orta’s personal

liability is based on her signing the agreement in her representative capacity.

The contract price between Monarch and Killian referenced a

“binding estimate” of $9,293.75 for the interstate shipment of household goods, and

within the contract, Killian agreed to several pertinent provisions.

First, the Fischers expressly waived insurance for the full replacement

cost of any goods damaged in transit or upon delivery through the bill of lading

addendum Theresa executed, which is required under federal law in order for the

waiver to be effective. See 49 U.S.C. 14706(f) (providing that unless the carrier

receives a waiver in writing for household goods, the maximum liability is an

amount equal to the replacement value of such goods subject to a maximum amount

as determined by the declared value of the shipment). The waiver clause,

implementing Section 1 of the parties’ agreement, advised the Fischers that

Monarch would be responsible for damages calculated by multiplying the actual

weight of the damaged goods by 60 cents. That clause was referred to as the “60

cent per pound per article” clause. The example given in the waiver clause provided

that if the mover damaged a piece of electronic equipment valued at $1,000, but it

weighed just ten pounds, the moving company’s liability was limited to $6.00. The implications of that provision of the contract were not addressed in the complaint

or discussed at trial.

In addition to the waiver of insurance for damaged goods, the

contract between the Fischers and Monarch included a choice-of-law provision,

contained in Section 11 of their agreement. That clause designated that any suits

involving the interstate shipment, which must be filed in Miami Dade County,

Florida, “must be limited to the governing federal law.” That language ostensibly

invokes the Carmack Amendment under 49 U.S.C. 14706. “The Carmack

Amendment is a federal statute that provides the exclusive cause of action for

interstate shipping contract claims, and it completely preempts state law claims

alleging delay, loss, failure to deliver and damage to property[,]” which includes

residential, household goods. White v. Mayflower Transit, L.L.C., 543 F.3d 581,

584 (9th Cir. 2008), citing Hall v. N. Am. Van Lines, Inc., 476 F.3d 683, 687-688

(9th Cir. 2007). The federal law impacts the viability of the CSPA claim the Fischers

advanced. See, e.g., Shemes v. United States Moving Serv., LLC, 2023 U.S. Dist.

LEXIS 176910, *9 (D. Kan. Oct. 2, 2023) (that federal law preempts common-law

contract and tort claims between a carrier and a shipper seeking recovery for that

loss or damage,” and therefore, the plaintiffs’ claims under Kansas’s version of the

state consumer-protection act were dismissed as against the carrier who moved,

stored, and shipped the property). The choice-of-law provision also included the

Fischers’ express consent to jurisdiction of local courts in Travis County, Texas. The Fischers allege that Monarch packed, stored, and moved their

household goods from Texas to Ohio. During the packing of the Fischers’ household

goods in Texas, Monarch allegedly refused to move a grill and artwork, valued at

$1,100, and demanded the second payment representing over 50 percent of the

contractual price, which was required under the terms of the contract. Upon

delivery of the household goods to Ohio, the Fischers claimed Monarch damaged

several items of personal property during the transit and temporary storage or upon

delivery, ruining $13,050 worth of goods. In addition, there is an allegation that the

agents also allegedly caused damage to the house as evidenced by photos of

scratches on drywall and in wood flooring.

It is not clear if Monarch provided the delivery services within Ohio

or whether a local independent contractor was involved. In the appellate briefing,

the Fischers refer to the delivery personnel as “agents” of Monarch and some

evidence introduced at trial indicated an independent contractor made the final

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Bluebook (online)
2024 Ohio 2812, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fischer-v-monarch-van-lines-llc-ohioctapp-2024.