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Davis v. Henderson

U.S.
Oct 27, 1924
266 U.S. 92 (1924)

Summary

In Davis v. Henderson, 266 U.S. 92, 45 S.Ct. 24, 69 L.Ed. 182 (1924), the Supreme Court held that an interstate carrier cannot waive compliance with tariff rules under the ICA, for "[t]he transportation service to be performed was that of common carrier under published tariffs.

Summary of this case from United Video v. N. Penn Transfer

Opinion

ERROR AND CERTIORARI TO THE SUPREME COURT OF THE STATE OF ARKANSAS.

No. 44.

Submitted October 8, 1924. Decided October 27, 1924.

1. A judgment of a state court rendered against an interstate carrier, when under federal control, through failure to give effect to a rule in its tariff, held reviewable by certiorari and not by writ of error. P. 93. 2. A tariff rule, approved by the Interstate Commerce Commission, providing that orders for cars given the carrier's local agent must be in writing, cannot be waived by the carrier through the agent's acceptance of oral notice from the shipper. Id. 157 Ark. 43, reversed.

ERROR and certiorari to a judgment of the Supreme Court of Arkansas affirming a judgment against a carrier in an action by a shipper for failure to furnish a car within a reasonable time after notice.

Mr. A.A. McLaughlin, Mr. Thomas B. Pryor and Mr. Vincent M. Miles, for plaintiff in error and petitioner.

No brief filed for defendant in error and respondent.


Henderson, a shipper of cattle, brought this suit in a state court of Arkansas against an interstate carrier then under federal control. The cause of action alleged was failure to furnish a car within a reasonable time after notice. The carrier defended on the ground that the shipper had not complied with a rule, approved by the Interstate Commerce Commission, and contained in its tariff, which provided that orders for cars must be placed with the local agent in writing. Written notice was not given. The plaintiff was permitted to testify that he had notified the station agent orally and that the latter had accepted his oral notice. The trial court refused to instruct the jury that the shipper could not recover without proving a notice in writing. Exceptions were duly taken. The plaintiff got the verdict; and the judgment entered thereon was affirmed by the highest court of the State. 157 Ark. 43. The carrier brought this writ of error; and, also, filed a petition for a writ of certiorari, consideration of which was postponed until the hearing on the writ of error. The former must be dismissed. Act of September 6, 1916, c. 448, § 2, 39 Stat. 726. The writ of certiorari is now granted.

There is no claim that the rule requiring written notice was void. The contention is that the rule was waived. It could not be. The transportation service to be performed was that of common carrier under published tariffs. The rule was a part of the tariff. Georgia, Florida Alabama Ry. Co. v. Blish Milling Co., 241 U.S. 190, 197; Missouri, Kansas Texas Ry. Co. v. Ward, 244 U.S. 383, 388; Davis v. Cornwell, 264 U.S. 560, 562.

Writ of Error dismissed.

Writ of Certiorari granted.

Judgment reversed.


Summaries of

Davis v. Henderson

U.S.
Oct 27, 1924
266 U.S. 92 (1924)

In Davis v. Henderson, 266 U.S. 92, 45 S.Ct. 24, 69 L.Ed. 182 (1924), the Supreme Court held that an interstate carrier cannot waive compliance with tariff rules under the ICA, for "[t]he transportation service to be performed was that of common carrier under published tariffs.

Summary of this case from United Video v. N. Penn Transfer

In Davis v. Henderson, 266 U.S. 92, the carrier's tariffs provided that orders for cars must be placed in writing with the local agent.

Summary of this case from Steindl v. New York Cent. R. Co.

In Davis v. Henderson, 266 U.S. 92, 45 S.Ct. 24, 69 L.Ed. 182, it was held that a tariff provision requiring orders for cars to be given in writing could not be waived by acceptance of oral notice.

Summary of this case from Gus Datillo Fruit Co. v. Louisville & Nashville Railroad

In Davis a cattle shipper brought suit against an interstate carrier for failing to provide a cattle car within a reasonable time after notice.

Summary of this case from United Video Buyers v. North Penn Transfer

In Davis v. Henderson, 266 U.S. 92, 45 S.Ct. 24, 69 L.Ed. 182 (1924) (Brandeis, J), the Supreme Court handed down the general rule applicable in this case: i.e., an interstate carrier cannot waive a rule which is part of its published tariff with respect to interstate shipments.

Summary of this case from United Video Buyers v. North Penn Transfer
Case details for

Davis v. Henderson

Case Details

Full title:DAVIS, AGENT, v . HENDERSON

Court:U.S.

Date published: Oct 27, 1924

Citations

266 U.S. 92 (1924)
45 S. Ct. 24

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