Total Quality Logistics, L.L.C. v. Am. Trucking, Inc.

2024 Ohio 5634, 259 N.E.3d 736
CourtOhio Court of Appeals
DecidedDecember 2, 2024
DocketCA2024-07-054
StatusPublished

This text of 2024 Ohio 5634 (Total Quality Logistics, L.L.C. v. Am. Trucking, Inc.) 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
Total Quality Logistics, L.L.C. v. Am. Trucking, Inc., 2024 Ohio 5634, 259 N.E.3d 736 (Ohio Ct. App. 2024).

Opinion

[Cite as Total Quality Logistics, L.L.C. v. Am. Trucking, Inc., 2024-Ohio-5634.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

CLERMONT COUNTY

TOTAL QUALITY LOGISTICS, LLC, : CASE NO. CA2024-07-054 Appellee, : OPINION : 12/2/2024 - vs - :

AMERICAN TRUCKING, INC., :

Appellant. :

CIVIL APPEAL FROM CLERMONT COUNTY COURT OF COMMON PLEAS Case No. 2022 CVH 00836

Giles & Harper, LLC, and Brian T. Giles, for appellee.

Barron, Peck, Bennie & Schlemmer, and Steven C. Davis, for appellant.

M. POWELL, J.

{¶ 1} Appellant, American Trucking Inc, ("American"), appeals the decision of the

Clermont County Court of Common Pleas granting summary judgment in favor of

appellee, Total Quality, Logistics, LLC ("TQL"). For the reasons stated below, we affirm

the judgment of the trial court.

{¶ 2} TQL is a freight broker that facilitates the transportation of freight for its Clermont CA2024-07-054

customers. American is a freight company that transports goods in interstate commerce.

On or about January 28, 2020, TQL and American entered into a Broker/Carrier

Agreement (the "Agreement"), whereby American agreed to provide third-party motor

carrier services to TQL's customers in exchange for payment.

{¶ 3} The Agreement included the following provisions:

4. COMPENSATION. . . .

...

(g). Notwithstanding any other provision in this Agreement to the contrary, [TQL] may offset against [AMERICAN]'s pending invoices for any amounts due to [TQL], including, without limitation, those arising from or related to cargo claims, [AMERICAN]'s breach of this Agreement, or [AMERICAN]'s indemnity obligations to [TQL] or CUSTOMERS.

8. CARGO LIABILITY AND CLAIMS. . . . [AMERICAN] is fully responsible and liable for the freight once in possession of it, and the trailer(s) is loaded, even partially, regardless of whether a bill of lading has been issued, signed, or delivered to [AMERICAN]. [AMERICAN]'s responsibility and liability shall continue until proper and timely delivery of the shipment to the consignee and the consignee signs the bill of lading or delivery receipt evidencing successful delivery . . .

10. INDEMNIFICATION. [AMERICAN] agrees to defend, indemnify, and hold [TQL] and CUSTOMERS harmless from and against any and all claims or liability (including, without limitation Workers' Compensation claims), arising out of or in any way related to [AMERICAN]'s negligence, willful misconduct acts, omissions, or performance or failure to perform under this Agreement, including, without limitation, claims or liability for cargo loss and damage, theft, delay, damage to property, and bodily injury and/or death . . .

-2- Clermont CA2024-07-054

22. GENERAL [AMERICAN] DUTIES. . . .

d. [AMERICAN] is responsible for any damage or loss to the product, shipment, or its packaging, and any and all shortages, from the time the shipment, or any portion thereof first comes into [AMERICAN]'s possession or control at pickup, until the shipment is no longer in [AMERICAN]'s possession or control at delivery.

23. [AMERICAN] DUTIES FOR REFRIGERATED LOADS. . . .

e. [AMERICAN] shall continuously maintain the temperature noted on [TQL]'s Rate Confirmation from pickup at shipper until delivery at receiver. [AMERICAN] shall not, at any time, set reefer on start/stop, cycle, or any other non-continuous temperature setting unless otherwise notified in writing by [TQL]. [AMERICAN] shall contact [TQL] immediately in the event of any problems including, without limitation, out-of-temperature condition, equipment malfunction accident, or delay.

{¶ 4} On July 9, 2021, TQL hired American to deliver a load of frozen pies. The

"Rate Confirmation," a document containing details on the load, issued by TQL to

American provided that American was to pick up the pies from the shipper in Worcester,

Massachusetts on July 9, 2021 between 8 a.m. and 3 p.m. and deliver them to the

consignee in York, Pennsylvania on the same day by 7 p.m. The Rate Confirmation

further provided that the pies be maintained at a temperature of -10F.

{¶ 5} An American driver picked up the pies as scheduled. However, the driver

encountered a prolonged delay due to a traffic accident on an interstate highway. As a

result, the load did not arrive at consignee's facility on July 9, 2021 until approximately an

-3- Clermont CA2024-07-054

hour past the scheduled delivery time. Upon arrival, the American driver was directed to

wait in a parking lot. After waiting several hours, the consignee declined to accept the

pies because of American’s late arrival and advised the American driver to leave the

premises.

{¶ 6} Thereafter, the delivery of the pies was rescheduled multiple times until July

15, 2021. On that date, however, the consignee rejected delivery because the pulp

temperature of the pies was between 50.3F and 60.2F, well above the specified -10F set

forth in the Rate Confirmation. TQL's customer subsequently submitted a claim to TQL

for the spoiled pies in the amount of $50,396. TQL paid and took an assignment of the

customer's claim. Consistent with paragraph 4(g) of the Agreement, TQL then offset the

claim with open invoices of American, and TQL demanded the balance of $30,896 from

American to pay for the spoiled pies. American refused to pay TQL.

{¶ 7} TQL filed a complaint against American in the Clermont County Common

Pleas Court asserting claims for breach of contract, unjust enrichment, quantum meruit,

damages under the Carmack Amendment, and breach of bailment. TQL's breach of

contract claim alleged that American had breached the Agreement by failing to deliver the

pies on time (i.e., by 7 p.m. on July 9, 2021) and by failing to maintain the pies at the

specified temperature of -10F. American answered and counterclaimed against TQL for

breach of contract and unjust enrichment.

{¶ 8} TQL later filed a motion for summary judgment on its claims and American's

counterclaims. TQL's motion for summary judgment asserted that there were no genuine

issues of material fact that American had breached the Agreement by failing to deliver the

pies on time, to maintain the pies at the specified temperature, and to indemnify TQL for

the claim it had paid. American filed a memorandum in opposition to TQL's motion for

summary judgment but only addressed TQL's argument related to the untimely delivery

-4- Clermont CA2024-07-054

of the pies. American did not address, argue, or submit any summary judgment evidence

related to TQL's claim that American failed to maintain the pies at the temperature

specified by the Rate Confirmation.

{¶ 9} The trial court granted summary judgment in TQL's favor on its breach of

contract claim and American's counterclaims. Although the trial court found there were

genuine issues of material fact related to whether American's arrival at the consignee's

facility approximately an hour later than the time specified in the Rate Confirmation was

a material breach of the Agreement, it found no genuine issues of material fact related to

American's failure to maintain the pies at the specified temperature, making summary

judgment proper.

{¶ 10} American appeals the trial court's decision, raising a single assignment of

error.

{¶ 11} FIRST ASSIGNMENT OF ERROR: THE TRIAL COURT ERRED IN ITS

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Bluebook (online)
2024 Ohio 5634, 259 N.E.3d 736, Counsel Stack Legal Research, https://law.counselstack.com/opinion/total-quality-logistics-llc-v-am-trucking-inc-ohioctapp-2024.