Robinson v. Memphis & C. R.
16 F. 57 (1883)
Rule of Law:
A common carrier is excused from its contractual duty to deliver goods when they are seized under valid legal process, but only if the carrier gives prompt and immediate notice of the seizure to the consignee and has not colluded with the seizing party.
Facts:
- A shipper named Chiles delivered 27 bales of cotton to the defendant, Memphis & C. R. Co., under a bill of lading held by the plaintiffs that called for 32 bales.
- The bill of lading identified the plaintiffs as the consignees (the intended recipients) of the cotton.
- The Bank of Madison, asserting an adverse claim to the cotton, demanded that the railroad turn it over.
- The railroad's agent promised the Bank of Madison that it would hold the cotton to allow the bank to initiate legal proceedings.
- Instead of shipping the cotton to the plaintiffs, the railroad held it as promised.
- The Bank of Madison then initiated a replevin action against the railroad, and the cotton was seized from the railroad's possession under legal process.
- The railroad did not provide any notice to the plaintiffs of this seizure until several months had passed.
Procedural Posture:
- The Bank of Madison filed a replevin action against the Memphis & C. R. Co. (defendant), and the cotton was seized by a court officer.
- The plaintiffs sued the defendant in federal court for breach of contract for failure to deliver the cotton.
- At trial, the defendant asserted the seizure under legal process as a complete defense to its non-delivery.
- The jury returned a verdict in favor of the plaintiffs.
- The defendant then filed a motion for a new trial, arguing the court erred in its instructions regarding the defense of seizure by legal process.
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Issue:
Does a common carrier's failure to provide prompt notice to the consignee of a seizure of goods under legal process prevent the carrier from using that seizure as a valid defense against a claim for non-delivery?
Opinions:
Majority - Hammond, J.
Yes. A common carrier's failure to provide prompt notice to the consignee of a seizure under legal process prevents the carrier from using that seizure as a defense for non-delivery. While seizure under valid legal process is generally an excuse for non-delivery, akin to an act of God, this defense is not absolute. A carrier, as a bailee, has a continuing duty to protect the goods, which includes promptly notifying the owner of any legal action so they may defend their title. Without such notice, the carrier remains strictly liable for non-delivery, just as if it had voluntarily delivered the goods to a wrongful claimant. The court also found that the carrier's promise to hold the cotton for the adverse claimant constituted collusion, which independently defeated the carrier's defense.
Analysis:
This decision refines the rule established in Stiles v. Davis, which recognized seizure by legal process as a defense for a common carrier. The court here adds a critical condition: the carrier must provide prompt notice to the goods' owner. This holding reinforces the high duty of care owed by carriers, treating their role not just as transporters but as protectors of the bailor's property interests. By requiring notice, the decision ensures that owners are not deprived of their property without an opportunity to be heard, and it prevents carriers from passively allowing seizures to escape liability. This precedent places an affirmative duty on carriers to act in their customers' best interests when faced with third-party legal claims.
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