United Fruit Co. v. New York & Baltimore Transportation Co.

2 Balt. C. Rep. 413
CourtBaltimore City Superior Court
DecidedJune 5, 1906
StatusPublished

This text of 2 Balt. C. Rep. 413 (United Fruit Co. v. New York & Baltimore Transportation Co.) is published on Counsel Stack Legal Research, covering Baltimore City Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United Fruit Co. v. New York & Baltimore Transportation Co., 2 Balt. C. Rep. 413 (Md. Super. Ct. 1906).

Opinion

SHARP, J.—

The plaintiff in this case sues the defendant, a common carrier, for the value of goods destroyed by the lire of February 7th and 8th, 1904.

The goods were the property of the plaintiff, and had been delivered to the defendant in New York on February 1st, 2nd and 3rd, 1904, in a number of packages by several persons, from whom the plaintiff had purchased them. Formal bills of lading were issued in some cases, in others, receipts for the goods were given, but in all cases, except five, the goods were consigned to the plaintiff, and the destination was expressed to be “No. 205 Bowly’s Wharf, Baltimore.”

The goods were safely transported from New York to the city of Baltimore. The vessel arrived Friday, February 5th, 1904, about 6.30 A. M., at Union Dock, the terminus of the defendant’s line in Baltimore. The plaintiff was notified before noon on Friday that the goods had arrived and that the defendant was ready to deliver immediately.

There was some conflict in the testimony in relation to the transactions between the parties after this notice was given, and to ascertain precisely what was said and done by the agents of the parties would be a very difficult task. The witnesses, however, substantially agree on the following facts, which are conclusive.

As the facts about which there was a conflict do not affect the case, they may be left out of consideration.

The defendant proposed to deliver the goods on Friday, but the plaintiff was not ready to receive them, and requested a postponement of the delivery until the following Tuesday. The plaintiff is a merchant engaged in foreign trade, and the goods were to be exported.

On the following Tuesday, a vessel of the plaintiff would be at Bowly’s Wharf loading for a voyage. It would be less expensive and troublesome to the plaintiff to postpone the delivery until Tuesday, and then deliver by scows directly to the vessel, instead of delivering at Bowly’s Wharf on Friday. A delivery on Friday would require the plaintiff to store the goods at Bowly’s Wharf until the vessel arrived. This would have involved extra expense, particularly in the cost of handling the goods. It was, at the suggestion of the plaintiff’s agent, agreed by the parties that the goods should not be delivered on Friday, as proposed by the defendant, but retained by it until Tuesday, and then delivered by scows to the plaintiff’s vessel.

The vessel of the defendant on which the goods had been brought to Baltimore was to sail on Saturday. After the arrangement was made to defer the delivery until Tuesday, the goods were taken out of the vessel and placed on the defendant’s wharf, a safe and suitable place, to be kept until the following Tuesday, and then to be delivered by scows to a vessel at Bowly’s Wharf.

On Monday, February 8th, the goods were destroyed in the great fire.

The plaintiff contends that the defendant is liable as carrier and, therefore, as insurer of the goods. The defendant claims to be liable as warehouseman, and responsible only for loss caused by negligence. The claim of the plaintiff is on the theory that the contract was to deliver at No. 205 Bowly’s Wharf, and there having been, in fact, no delivery at that place, or any refusal to receive the goods, but delivery having been postponed by agreement until the following Tuesday, the journey contemplated by the original con[414]*414tract was unfinished, and the goods still in the possession of the defendant as carrier.

The plaintiff further contends, if his first contention is not well founded, that the agreement of Friday for a postponement of the delivery until Tuesday must be regarded as a new contract to transport the goods from Union Dock to Bowly’s Wharf, and the defendant, having received the goods to be transported, is liable as carrier.

The severe and peculiar liability of a carrier is one imposed by public policy, on account of the risks attending transportation, and the difficulty of ascertaining the cause of and fixing the responsibility for any loss. The owner loses sight of his goods, and to obtain evidence of negligence is generally impracticable. For these reasons the carrier is held responsible, without regard to negligence, for all loss or injury to the goods, except those caused 'by the act of God, the public enemy, public authority, or the nature of the goods. The carrier is called an insurer.

When a carrier received goods, to be transported, he is ordinarily liable as insurer from the moment he receives the goods, though they are lost when in a warehouse before the journey has begun. In such a case the deposit is a mere incident of the carriage. The liability of a carrier in connection with the delivery of the goods on the completion of the journey is not so well settled.

It has been held in some States (“Mass. Doctrine”) that when the journey is finished, and the goods removed from the vessel or car to the warehouse of the carrier, his liability is that of a warehouseman, irrespective of any action by the consignee, 5 Ency. of law, 263; but in other States (“New Hampshire Doctrine”) it has been held that the liability of a carrier as insurer does not terminate on the arrival of the vessel, or the train, and the storage of the goods in a warehouse, but continues until the consignee has had a reasonable opportunity to take the goods into his possession. 5 Ency. of Law, 264.

The consignee is bound to take possession of the goods within a reasonable time. If he refuses, or neglects to do so, the carrier’s liability changes to that of a warehouseman, and he is liable only for negligence. The owner cannot insist that the carrier shall retain the goods subject to the severe obligations of an insurer, after the reasons for such obligations have entirely ceased to exist.

M. & M. T. Co. vs. Story, Md., 4.

But whatever conflict there may be on these points, it is well settled, that where the goods are in a warehouse and the delay, either in the commencement of the journey, or of the delivery of the goods to the consignee, after the journey has been completed, is the act of the owner, and not of the carrier, the liability of the latter is that of warehouseman.

5 Ency. of L., 260.

St. L., &c., R. R. vs. Montgomery, 39 Ill., 335.

Ill. C. E. R. Co. vs. Tronstine, 64 Miss., 834.

O’Neill vs. N. C. & H. R. R. R., 80 N. Y., 138.

Platt vs. Hibbard, 7 Cowen, 497.

P. C. & St. L. R. R. Co. vs. Barrett, Ohio St., 448.

Schmidt vs. C. & N. R. R. Co., 90 Wisconsin, 504.

Moses vs. B. & M. R. R. Co., 4 Foster, 71.

Watts vs. B. & L. R. R. Co., 106 Mass., 466.

Goodbar vs. Wabash, &c., R. R., 53 Mo. Ap. 434.

In this case the defendant transported the goods safely .from New York to Baltimore. The plaintiff was notified on Friday morning that the carrier was ready to deliver them, but the plaintiff was not ready to receive them. The delay in the delivery was not the fault of the carrier. It was at the plaintiff’s suggestion and for his convenience, that the delivery was postponed until Tuesday.

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Bluebook (online)
2 Balt. C. Rep. 413, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-fruit-co-v-new-york-baltimore-transportation-co-mdsuperctbalt-1906.