Rohner Gehrig Company, Inc. v. Tri-State Motor Transit

923 F.2d 1118, 1991 U.S. App. LEXIS 2455, 1991 WL 8494
CourtCourt of Appeals for the Fifth Circuit
DecidedFebruary 15, 1991
Docket89-6246
StatusPublished
Cited by6 cases

This text of 923 F.2d 1118 (Rohner Gehrig Company, Inc. v. Tri-State Motor Transit) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rohner Gehrig Company, Inc. v. Tri-State Motor Transit, 923 F.2d 1118, 1991 U.S. App. LEXIS 2455, 1991 WL 8494 (5th Cir. 1991).

Opinions

FILEMON B. VELA, District Judge:

Tri-State Motor Transit (Tri-State) appeals a grant of summary judgment in favor of the plaintiff Rohner-Gehrig (Roh-ner) and a denial of its motion for summary judgment. Based upon the record before us we find that the district court did not have sufficient grounds to grant Rohner summary judgment but was warranted in denying Tri-State’s motion for summary judgment. We therefore REVERSE in part and AFFIRM in part.

I. The Facts.

When it absolutely positively has to get there.

In 1906, Congress enacted the Carmack Amendment (now at 49 U.S.C. § 11707 [1120]*1120[Supp.1990]) which prohibited carriers from limiting their liability in any way.2 As a result, carriers began to charge exorbitant rates for shipments insured at full value. Congress reacted by enacting the Cummings Amendment (now at 49 U.S.C. § 10730 [Supp.1990]) which allows carriers to limit liability, but gave the ICC the power to approve rates through “tariffs.” 3 A tariff is a document filed by the carrier and published by the ICC listing several freight rates available to shippers for different types of equipment. The tariff is not part of the bill of lading given to the shipper, but rather a separately published document incorporated by reference into the bill of lading.

Each rate in a tariff carries a corresponding level of liability per pound which is termed a “released rate.” A higher freight rate, therefore, secures a higher level of liability. When a tariff contains an inadvertence clause4 and a shipper fails to declare a value in the bill of lading, then the shipper is insured at the lowest rate permitted in the tariff. The inadvertence clause is usually incorporated into the bill of lading in the released rate clause by a sentence which states that if the shipper fails to state a released rate, the shipment is deemed released at the lowest rate or the rate listed. The shipper, therefore, is not compelled to accept the given released rate but may instead choose a higher rate by incorporating it into the bill of lading.

Truckin’. Got my chips cashed in.

Tri-State contracted with Rohner to ship an airplane tail assembly from Tinker Air Force Base in Oklahoma to Houston, Texas. The French Military owns the assembly and Rohner is its subrogee.

Gordon Burnett, a freight rate specialist for the Air Force signed Tri-State’s freight bill (the bill of lading) as “shipper per” and as the consignor. Mr. Burnett had seven years experience as a shipping agent for the U.S. Air Force and was familiar with bills of lading and the general effect of a released rate. He did not declare a greater released rate or value for the cargo than that provided by the released rates found in the tariffs.5

[1121]*1121In the center of the Tri-State’s freight bill, above Mr. Burnett’s signature, appears the released rate clause:

Unless a Greater Value is Declared, The Shipper Hereby Releases the Value to $5,000.00 Per Ton of 2,000 Pounds for Each Article.

This portion of the shipping order (freight bill) was not set off in bold letters nor was it in larger type than the rest of the bill. Neither was there a space specifically provided for the shipper to declare a greater value as required by tariff NAS 190-A.

During shipment, the freight was damaged. Tri-State does not contest its liability, but contends that Rohner’s damages are limited to the released value damages as set forth in the shipping order and in the lawfully filed tariffs applicable to the transportation of the cargo in question.

The district court found that Tri-State’s bill of lading failed to comply with the tariff provisions and therefore, the released rate clause was void. Therefore, TriState’s motion for summary judgment was denied and Rohner’s granted.

II. The Law.

Although this court has not ruled on this precise issue, it and others have enforced bills of lading that substantially (rather than strictly) comply with their related tariffs. Eg., Robinson v. Ralph G. Smith, Inc., 735 F.2d 186, 190 (6th Cir.1984); Strickland Transp. Co. v. United States, 334 F.2d 172, 179 (5th Cir.1964). The district court did not address what test this circuit would use because it found “TriState’s bill of lading fails to even substantially comply with the tariff.” “Where, as here, questions of law control the disposition on summary judgment, we must subject the controverted issues to full appellate review.” Texas Commerce Bank-Fort Worth, N.A. v. United States, 896 F.2d 152, 155 (5th Cir.1990) (citing Barrett Computer Services, Inc. v. PDA, Inc., 884 F.2d 214, 215 (5th Cir.1989)).

Limitation of Liability

In order for the Cummings Amendment to limit liability, the carrier must satisfy four requirements; he must “1) maintain a tariff within the prescribed guidelines of the Interstate Commerce Commission; 2) obtain the shipper’s agreement as to his choice of liability; 3) give the shipper a reasonable opportunity to choose between two or more levels of liability; and 4) issue a receipt or bill of lading prior to moving the shipment.” Hughes v. United Van Lines, Inc., 829 F.2d 1407, 1415 (7th Cir.1987), cert. denied, 485 U.S. 913, 108 S.Ct. 1068, 99 L.Ed.2d 248 (1988) (citing Anton v. [1122]*1122Greyhound Van Lines, Inc., 591 F.2d 103 (1st Cir.1978)). The first and last requirements are evidentiary in nature and are not at issue in this case.6 The law in this circuit, however, must be clarified in regards to the second and third elements.

A. Shipper’s Agreement

What must occur in order for a shipper to give his agreement as to his choice of liability? “Shippers are charged with notice of terms, conditions and regulations contained in the tariff schedule pertaining to a carrier’s liability which in turn affect the rates charged the carriage of goods.” Anton v. Greyhound Van Lines, Inc., 591 F.2d 103, 108 (1st Cir.1978) (citing American Railway Express Co. v. Daniel, 269 U.S. 40, 42, 46 S.Ct. 15, 15, 70 L.Ed. 154 (1925)).

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923 F.2d 1118, 1991 U.S. App. LEXIS 2455, 1991 WL 8494, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rohner-gehrig-company-inc-v-tri-state-motor-transit-ca5-1991.