Adams Express Company v. Croninger

Citations

• 226 U.S. 491
• 33 S. Ct. 148
• 57 L. Ed. 314
• 1913 U.S. LEXIS 2256

Syllabus

<p>The constitutional power of Congress to regulate commerce among the States and with foreign nations comprehends power to regulate contracts between shipper- and carrier of shipments in such eom- . merce in regard to liability for loss or damage to articles carried.</p> <p>Until Congress has legislated upon that subject, the liability of a carrier, although engaged in interstate commerce, for loss or damage to ■property carried, may be regulated by law of the State.</p> <p>Since the decisions of this court in Chicago, Milwaukee & St. Paul Railway v. Solan, 169 U. S. 133, and Pennsylvania Railroad v. Hughes, 191 U. S. 477, Congress has by § 20 of the Hepburn Act of June 29, 1906, 34 Stat. 684, c. 3591, known as the Carmack amendment, legislated directly upon the carrier’s liability for loss of and damage to interstate shipments, and this legislation supersedes all regulations and policies of a particular State upon the same subject.</p> <p>Only the silence of Congress authorizes the exercise of the police power of the State upon the subject of contracts with carriers for interstate shipments, and when Congress exercises its authority the regulating power of the State is at an end.</p> <p>In enacting the Carmack amendment it is evident that Congress intended to adopt- a uniform rule as to the liability imposed upon interstate carriers by state regulations of bills of lading and to relieve such contracts from the diverse regulation to which they had ■ theretofore been subject.</p> <p>A proviso reserving certain rights of action will not be construed as nullifying the statute itself and maintaining the existing .confusion which it was the purpose of Congress to put an end to; and so held that the proviso in the Carmack amendment related to remedies under existing Federal law at the time of this action and not to any state law.</p> <p>A rational interpretation will be given to a statute and a proviso and not one by which the statute will, through the proviso,.destroy i