Air Products & Chemicals, Inc. v. Illinois Central Gulf R.R. Co

In Air Products & Chemicals, Inc. v. Ill. Central Gulf R.R. Co., 721 F.2d 483, 484-85 (5th Cir.1983) the Court held that "the Carmack Amendment, as judicially interpreted, provides an exclusive remedy for a breach of contract of carriage provided by a bill of lading." The Court concluded that "Congress intended by the Carmack Amendment to provide a uniform national remedy against carriers for breach of the contract of carriage, including a liability for default in any common-law duty as a common carrier." Id. at 487. In Air Products & Chemicals, Inc. v. Illinois Central Gulf R.R. Co., 721 F.2d 483 , 485-86 (5th Cir. 1983) the Court stated the following: "Despite the apparent statutory limitation to recovery of damage caused to the property itself transported, the Supreme Court . . . from its earliest interpretation has consistently construed the Carmack Amendment as likewise imposing liability upon the carrier for all reasonably foreseeable consequential damages resulting from a breach of the contract of carriage, including those resulting from nondelivery of the shipped goods as provided by the bill of lading. . . . This broad interpretation of a carriers liability under its bills of lading was premised upon what the Court conceived to be a paramount object of the legislation to provide a uniform rule that the carrier issuing the bill of lading would be responsible to the consignee for all loss, damage, or delay arising out of the contract to transport the goods so shipped."