Chicago, Rock Island & Pacific Ry. Co. v. Cramer, 232 U.S. 490 (1914)

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Chicago, Rock Island & Pacific


Railway Company v. Cramer
No. 156


Submitted January 16, 1914
Decided February 24, 1914
232 U.S. 490

ERROR TO THE SUPREME COURT
OF THE STATE OF IOWA

The Hepburn Act of 1906, amending the Interstate Commerce Act, established a uniform rule of liability of carriers for loss on interstate shipments which superseded all state laws upon the subject. In enforcing liability of the carrier for interstate shipments, the provisions in the regularly filed tariff enter into and form part of the contract of shipment, and if that tariff offers two rates based on value and the shipper declares the lower value so as to avail of the lower rate, the carrier may avail of the lower value so declared. Kansas Southern Ry. v. Carl, 227 U.S. 639.

In this case, the liability of the interstate carrier on an interstate shipment from Iowa was limited to the declared value notwithstanding § 2074, Iowa Code, prohibited such a defense.

153 Ia. 103 reversed.

The facts, which involve the construction of the Carmack Amendment to the Hepburn Act and its effect on state statutes, are stated in the opinion.