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
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- recognizing that 19th century federal common law governing carriers was “that of the general common law”
- holding cases interpreting the Carmack Amendment “clearly establish that the doctrine of complete pre-emption eliminates state law claims against carriers”
- stating that the Carmack Amendment “embraces the subject of the liability of the carrier” so completely that it “supersede[s] all state regulation with reference to it”
- stating that Car-mack Amendment “embraces the subject of the liability of the carrier under a bill of lading which he must issue and limits his power to exempt himself by rule, regulation or contract”
- stating that Carmack Amendment “embraces the subject of the liability of the carrier under a bill of lading which he must issue and limits his power to exempt himself by rule, regulation or contract”
- saving clause will not sanction state laws that would nullify policy expressed in federal statute; \the act cannot be said to destroy itself\ (internal quotation marks omitted)
Source: CourtListener parenthetical corpus (CC0).
Judges: Lurton
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
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