Justia Transportation Law Opinion Summaries

The insured was driving his pickup truck when he was injured after swerving to avoid a cardboard box lying in the middle of his lane. Allstate stipulated that an unidentified vehicle dropped the box, but rejected a claim for uninsured motorist benefits and sought a declaratory judgment. The insured responded with counterclaims for breach of contract and insurance bad faith under 42 Pa. Cons. Stat.8371. The district court entered judgment for Allstate, finding that the injuries did not "arise out of ownership, maintenance or use of an uninsured auto." The Third Circuit reversed, rejecting an argument that the harm was caused by a box, not a vehicle. Physical contact with an uninsured vehicle is not required for an accident to "arise out of" the use of an uninsured vehicle. Accepting for purposes of appeal that an unidentified vehicle that dropped the box was an uninsured vehicle, there is a sufficient causal connection. The court noted that the insurance law is to be liberally construed in order to afford the greatest possible coverage to injured claimants. View "Allstate Prop. & Cas. v. Squire" on Justia Law

This case involved the Carmack Amendment to the Interstate Commerce Act, 49 U.S.C. 14706, which set up a framework for the timely filing of claims against carriers for damaged cargo. In this case, it was undisputed that neither the shipper nor the shipping broker filed either a claim or a lawsuit within the prescribed time limitations. Therefore, were the court to create some exception to the statutorily authorized, contractually mandated requirements of prompt filing, the court would blow a hole in the balance struck by the Carmack Amendment and undermine Congress's intent to protect carriers against stale claims. Therefore, the court reversed the judgment of the district court in favor of the shipping broker and remanded with instructions to dismiss the lawsuit. View "Dominion Resources Serv. v. 5K Logistics, Inc." on Justia Law

Plaintiff, a freight railroad, owned a spur line connecting to a plastics plant, the only shipper located on the spur. Defendant, another railroad, bought the lines, including the spur. The sales contract allowed plaintiff to continue to run trains on the lines being sold and granted plaintiff an exclusive easement to use the spur to serve the plant. Several years later, the plant entered receivership. The receiver sold all assets, including the plant. The buyer continues to manufacture plastics in the plant. Contending that the change in ownership voided the exclusive easement, defendant contracted with the buyer to ship products over the spur, leaving plaintiff with diminished use of the spur. The district court ruled in favor of defendant, reasoning that the contract referred specifically to the plastics company in business at that time. The Seventh Circuit affirmed, based on the language of the contract in light of extrinsic evidence, and rejected a trespass claim. View "Dakota, MN & E. R.R. v. WI & S. R.R." on Justia Law

Appellants sued appellee under 49 U.S.C. 14103(a) for the reimbursement of fees associated with the loading and unloading of its trucks at appellee's facilities. Appellants subsequently appealed the district court's grant of summary judgment. The court concluded that the district court properly read section 14103(a) to preclude relief for unreimbursed "lumping" absent a plaintiff-trucker's affirmative showing that he or she was not reimbursed by either the shipper or the receiver. Therefore, the court affirmed the district court's order of summary judgment where appellants failed to identify any of its trucks whom a shipper had not already reimbursed. View "Owner-Operator Independent Drivers Assoc., et al. v. Supervalu, Inc." on Justia Law

The State brought a complaint against BNSF Railway Co. ("BNSF") in November 2009 seeking a declaratory judgment requiring BNSF to abide by the terms of a 1984 agreement between them and a declaration that BNSF was in violation of that agreement; specific performance by BNSF of the agreement, and damages for BNSF's alleged breach of the agreement. The State subsequently filed an application for a preliminary injunction in June 2010 to prohibit BNSF from terminating the payment to the State and its short line operator per loaded car for each car handled in interchanges as required by Section 9 of the agreement. At issue was whether the district court's order granting the preliminary injunction was an abuse of discretion. The court held that the district court manifestly abused its discretion in issuing the preliminary injunction where it went beyond the State's requested relief and effectively ordered specific performance on the agreement under new terms substantially different than the prior agreed upon terms which severely limited termination of the new interchange agreement and was never part of the 1984 or 1986 agreements. Accordingly, the court reversed the order and resolved the injunction, remanding for further proceedings.

QT Trading, L.P. ("QT") sued defendants for rust damage to its steel pipes that allegedly occurred during their transport from Dalian, China to Houston, Texas. At issue was whether the district court properly granted summary judgment to in personam defendants on QT's claims for damages under the Carriage of Goods at Sea Act ("COGSA"), 46 U.S.C. 30701 note (Carriage of Goods by Sea), and for negligent bailment of its goods. The court affirmed summary judgment and held that the district court properly dismissed QT's COGSA claims where QT failed to establish genuine issues of material fact where none of the defendants were "carriers" and thus could not be liable for damages under the statute. The court also held that the district court properly dismissed QT's bailment claims where QT failed to show that a certain defendant had exclusive possession of the cargo.