Adams Express Co. v. Croninger

In Adams Express Co. v. Croninger, 226 U.S. 491, the plaintiff hired the defendant, a common carrier, to ship a package containing a diamond ring from Ohio to Georgia. The package never arrived. The bill of lading stated that charges for delivering the package were based on the value of the shipment, that the value was to be declared by the shipper, and that failure to declare the value would result in a rate based on a value of $ 50. The plaintiff had not declared a value. Nevertheless, he brought suit against the defendant in Kentucky state court for the full market value of the ring. Under Kentucky law, the contract to limit the plaintiff's recovery to an agreed or declared value was invalid, and the plaintiff was generally entitled to recover the actual value of the ring. The plaintiff prevailed, and the case eventually went to the Supreme Court. The primary issue before the Court was whether a contract for an interstate shipment, as evidenced by a bill of lading, was governed by 'the local law of the state, or by the acts of Congress regulating interstate commerce.' Adams, 226 U.S. at 500 ... The Court noted that before the Carmack Amendment, the liability of common carriers for an interstate shipment of property was governed by either 'the general common law'--as pronounced by the state and federal courts--or the statutory laws of the states. Id. 226 U.S. at 504, ... Because of the many varying laws that might apply to a dispute arising out of any given interstate shipment of goods, it was impossible for interstate shippers and carriers to determine their risks and responsibilities with any reasonable certainty. See id. at 505 ... The Carmack Amendment, the Court held, 'made an end to this diversity, for the national law is paramount and supersedes all state laws as to the rights and liabilities and exemptions created by such transactions.' Id.