Welsh v. Pittsburg, Fort Wayne & Chicago Railroad

10 Ohio St. (N.S.) 65
CourtOhio Supreme Court
DecidedDecember 15, 1859
StatusPublished

This text of 10 Ohio St. (N.S.) 65 (Welsh v. Pittsburg, Fort Wayne & Chicago Railroad) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Welsh v. Pittsburg, Fort Wayne & Chicago Railroad, 10 Ohio St. (N.S.) 65 (Ohio 1859).

Opinion

Scott, J.

At common law, it has been long settled that the common carrier is responsible for the safe transportation and delivery of goods received by him for carriage, and can only justify or excuse a default, when occasioned by the act of God or the public enemies. He is not only responsible for his own acts of malfeasance, misfeasance, and negligence, in the course of his employment, but he is also regarded as an insurer against all loss or damage which may happen to goods, while in his charge, for the purposes of his employment, though occasioned by unavoidable accident, or by any casualty whatever, except only as above mentioned, And the burden of proof is thrown upon him, in bringing any particular case within the exceptions. For, ■ in the absence of proof, the loss itself raises the presumption of negligence on the part of the carrier.

This extent of liability and unfavorable presumption, to which the carrier is subjected by common law, is supposed to be justified by grave considerations of public policy, growing out of the char-acter of his employment. And we may safely say, that experience has amply vindicated the practical wisdom and propriety of the rule.

As to the power of the common carrier to restrict or limit this high degree of responsibility which is imposed upon him by the [56]*56common law, the authorities are by no means agreed, either as to the extent to which such limitation may be carried, or the mode in which it may be effected. The English decisions generally, as well as many in this country, recognize the right of the carrier to limit and qualify his liability by general notice, brought home to the knowledge of the owner of the goods, and not objected to by him. His acquiescence in such cases has been inferred from his-silence. But it has been forcibly urged, on *the other hand, that where a party is under obligation to carry upon the general terms of liability imposed by the law, it is more reasonable to infer, from the silence of the parties, that the carrier receded from terms which he had no right to impose, that than the customer waived what he had a legal right to demand. It has accordingly been uniformly held, in this state, that the common' carrier can not thus relieve himself from responsibility by his own act. Jones v. Voorhes, 10 Ohio, 145; Davidson v. Graham, 2 Ohio St. 131; Graham & Co. v. Davis & Co., 4 Ohio St. 362.

But that the liability of the carrier may be qualified and limited, by special contract, is well settled. It is true that even this right was denied, upon grounds of public policy, in New York, in the case of Cole v. Goodwin, 19 Wend. 251, and in the subsequent case of Gould v. Hill, 2 Hill, 623. But these have been since overruled. Parsons v. Monteath, 13 Barb. 353; Dorr v. N. J. Steam Nav. Co., 4 Sandf, 136; Stoddard v. The Long Island R. R. Co., 5 Sandf. 180. The authority of Gould v. Hill was also denied by the Supreme Court óf the United States, in the case of The N. J. Steam Nav. Co. v. Merchants’ Bank, 6 How. 344. That such restriction may be provided for by contract, has been affirmed in. this state, in the cases already referred to, in 2 and 4 Ohio St.

But to what extent this exemption from liability may be affected by the special contract of the parties, is a question of much importance, and upon which the authorities are less uniform.

Many of the English cases seem to recognize the right of a common carrier to stipulate for exemption from all liability, oven for gross neglect or positive misfeasance. Thus, in Maving v. Todd, 1 Starkie, 59, it was held, by Lord Ellenborough, that common carriers may make their own terms, and wholly exclude their responsibility ; to which he adds, “ I am sorry the law is so ; it leads to very great negligence.” And in Leeson v. Holt, 1 Starkie, 148, *where the carrier had given notice that articles of the par-. [57]*57ticular kind involved in that case, were to be entirely at the risk .of the owners, as to damage, breakage, etc., Lord Ellenborough, in summing up to the jury, said: “In the present ease the carriers seem to have excluded all responsibility whatever, so that, under the terms of the present notice, if a servant of the carriers had, in the most willful and wanton manner, destroyed the furniture intrusted to them, the principals would not have been liable. If the parties have so contracted, the plaintiff must abide by the agreement.” So in the much more recent case of Chippendale v. The Lancashire and Yorkshire Railway Co., 7 Eng. L. and Eq. 395, which, in its circumstances, closely resembles the case at bar. In that case the plaintiff had received from the railway company a ticket for cattle which were to be conveyed for him on the company’s road. This ticket was signed by the plaintiff, and contained at the bottom the following clause: “ N. B. This ticket is issued subject to the -owner undertaking all risks of conveyance whatever, as the company will not be liable for any injury or ■damage, howsoever caused, and occurring to live stock of any description, traveling upon the L. & Y. Railway, or in their vehicles.” The plaintiff saw the cattle put into the truck. Some of the cattle broke out of the truck on the journey and were injured ; and the jury having found, that the truck in question was so defectively constructed as to be unfit and unsafe for the purpose of conveying ■cattle along the line, assessed the plaintiff’s damages. 'The court nevertheless directed a verdict to be entered for the defendant, holding the company protected from liability by the'terms of the ticket. This judgment was affirmed by the court of Queen’s bench.

This decision, with several others to the same effect, was since the enactment of the common carrier’s act of 11 Geo. 4, and 1 Will. 4, chap. 68, by the 6th section of which all cases of special contract are excepted from its operation. These decisions, under that act, seem to establish, in England, *the right of the common carrier, by express contract, to exempt himself from liability for any thing short of actual malfeasance.

Biit in this country, whilst the right of a carrier is generally recognized to contract for exemption from that extraordinary responsibility imposed by the common law, which makes him an insurer, yet the validity of contracts providing for exemption from liability for his own misfeasance or gross negligence, has been frequently, if not generally, denied, upon grounds of public policy. In the [58]*58case of the N. Jersey Steam Nav. Co. v. Merchants’ Bank, 6 Howard, 344, it was held by the Supreme Court of the United States-, that a common carrier may, by contract, divest himself of that character, in respect to any particular transaction, so as to incur only the responsibility of an ordinary'bailee for hire, and be liable' for misconduct or negligence only. In Sager v. Portsmouth, S. & P. & E. Railroad Co., 31 Maine, 228, it was held that a common carrier is liable for the damages occasioned by his negligence or misconduct, notwithstanding a notice or contract to the contrary ; and also that the want of suitable vehicles, in which to transport articles, is negligence on the part of a carrier.

In some cases a distinction has been taken between the degrees of negligence, which, in the case of railroad transportation, is not always of easy application.

Mr. Story, in his Commentaries on the Law of Bailments, section 562 (6 ed.), on the authority of Chippendale v. L. & Y. Railway Co., 7 Eng.

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Related

Parsons v. Monteath & Hazard
13 Barb. 353 (New York Supreme Court, 1851)
Cole v. Goodwin & Story
19 Wend. 251 (New York Supreme Court, 1838)
Stoddard v. Long Island Rail Road
5 Sandf. 180 (The Superior Court of New York City, 1851)

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Bluebook (online)
10 Ohio St. (N.S.) 65, Counsel Stack Legal Research, https://law.counselstack.com/opinion/welsh-v-pittsburg-fort-wayne-chicago-railroad-ohio-1859.