## Facts

- Shippers sent a carload of potatoes from Michigan to Richmond, Virginia under a through interstate bill of lading.
- The delivering carrier was Chesapeake & Ohio Railway (C&O), which had been notified to deliver all such shipments to Bowman Transfer Company’s warehouse in Richmond.
- The shipment arrived in C&O’s Richmond yards six days after departure; four days later, the shippers inspected the potatoes, paid freight and demurrage, and became entitled to delivery.
- Completing delivery to Bowman required transfer over the Southern Railway, which ordinarily took no more than 48 hours.
- C&O transferred the car to the Southern Railway but mistakenly directed delivery to Harwood’s warehouse rather than Bowman’s; the potatoes were unloaded and stored at Harwood’s warehouse.
- Bowman erroneously issued a warehouse receipt to the shippers, later notifying them the receipt was mistaken and the car had been delivered to Harwood.
- The shippers visited Bowman’s warehouse and concluded the potatoes were there, but did not inquire of C&O or Harwood.
- Harwood later informed the shippers (May 10, 1926) that he had the potatoes; they found them spoiled and sold them for a nominal amount.
- The bill of lading required written claims within six months after delivery, or, if delivery failed, within six months after a reasonable time for delivery had elapsed.
- The shippers gave written notice/claim on May 26, 1926.

## Issues

1. Whether compliance with a time-limiting written-claim provision in an interstate bill of lading is a federal question governed by federal law.
2. How to determine when a “reasonable time for delivery” has elapsed under a bill-of-lading claim clause where the shipment was misdelivered.
3. Whether the evidence could legally support a finding that the shippers’ written claim was timely under the contractual standard.
4. Whether negligent misdelivery estops a carrier from invoking the bill-of-lading written-claim requirement.

## Decision

- The U.S. Supreme Court reversed the judgment for the shippers.
- Compliance with the bill-of-lading time limitation was held to be a federal question governed by federal law.
- “Reasonable time for delivery” was defined as the time necessary to transport and make delivery in the ordinary course of business under the circumstances; on the undisputed facts, that time elapsed long before the May 26 written claim.
- Applying the standard used for directed verdict review to a demurrer to the evidence, the Court held the record was legally insufficient to allow a verdict for the shippers on timeliness.
- Misdelivery caused by misunderstanding or negligence did not estop the carrier from enforcing the contractual written-claim deadline.

## Legal Principles

- Compliance with time-to-claim provisions in interstate bills of lading is governed by federal law to ensure uniform rules for interstate carriage contracts.
- “Reasonable time for delivery” under a claim-filing clause is an objective measure: the time required for transportation and delivery in the ordinary course of business given the transaction’s conditions.
- A demurrer to the evidence is tested by the same rules as a motion for directed verdict: conflicts are resolved against the defendant, but the court must rule for the defendant where the evidence and reasonable inferences are legally insufficient for the plaintiff.
- A factfinder may not disregard uncontradicted testimony that is not reasonably open to doubt merely because the witness is employed by an opposing party.
- Carrier negligence or misdelivery does not bar enforcement of a uniform bill-of-lading stipulation requiring timely written claims after a reasonable time for delivery has elapsed.

## Conclusion

The Court held that federal law controls whether a shipper timely complied with an interstate bill of lading’s six-month written-claim requirement, that “reasonable time for delivery” is measured objectively by ordinary-course delivery time, and that misdelivery does not prevent the carrier from enforcing the contractual claim deadline.


Chesapeake & Ohio Ry. Co. v. Martin, 283 U.S. 209 (1931)