Adams v. Mills
In Adams v. Mills, 286 U.S. 397, 407-08, 52 S.Ct. 589, 76 L.Ed. 1184 (1932), plaintiff-consignees had been liable for the charges and had paid them, and the decision affirms their right to recover. Id. at 405-09, 52 S.Ct. 589.
But they had evidently been reimbursed for the charges by the consignors. Id. at 407, 52 S.Ct. 589.
Adams was at pains to make clear that "the rights of the shippers in the proceeds of the action will not be affected by the Court's decision," that those rights "might have been asserted by intervention" in the Commission proceeding, and that they might still be asserted. Id. at 407-08, 52 S.Ct. 589.
The Adams dictum thus seems to go no further than to suggest that where the party with the legal obligation to pay the carrier does so, and is reimbursed by another party, the reimbursing party can protect its interests and in some way participate in the action before the Commission.