Cleveland v. Beltman N. Am. Co.

Cleveland v. Beltman N. Am. Co.

Opinion

 [*374]  CARDAMONE, Circuit Judge:

This appeal brings before us a married couple whose household belongings, after being transported by movers from Iowa to New York, were found upon arrival to be badly damaged. When claims made against the moving company to obtain compensation proved unavailing, the instant litigation was commenced. In handling plaintiffs' claims, the moving company -- in a deliberate and determined effort to frustrate plaintiffs' collection of damages for their losses -- was guilty of foot-dragging and stonewalling. It did not deal fairly or in good faith with the couple.

Ordinarily, common law principles of equity leaven the law, softening its rigors so that the law's aim of administering justice fairly is not lost. But on occasion, and this is one, the equities urge a course that the law may not take. Here, a hope that conduct such as that shown by the moving company could result in an award beyond compensatory damages is doomed to disappointment. We must reckon with an area of interstate [**3]  commerce law that has been fully occupied by Congress' passage of a statute delineating what remedies are available, leaving no room for additional state or federal common law causes of action.

BACKGROUND

Plaintiffs' Move to New York

In August 1988 Donald and Christa Cleveland moved from West Des Moines, Iowa to Slingerlands, New York, a suburb of Albany. To prepare for the move, the Clevelands searched for a reputable moving company to carry their household goods and personal belongings. In a decision they have no doubt come to regret, they hired defendant North American Van Lines (North American) and North American's local agent in Des Moines, defendant Beltman North American Co., Inc. (Beltman). North American and Beltman (defendants) are common carriers as that term is defined by the Interstate Commerce Act, 49 U.S.C. § 10102(4) (1988).

Following the usual practice, the Clevelands, North American, and Beltman executed a shipping contract, commonly called a bill of lading. Under a standard bill of lading carriers are responsible for only 60 cents per pound for damaged items. Having recently purchased new furniture, the Clevelands worried [**4]  whether this reimbursement rate would adequately cover a loss they might incur were their belongings to be accidentally damaged or lost. Because of this concern, they purchased supplemental protection from the moving company at an additional cost of $ 320. The protection plan, which was incorporated into the bill of lading, provided for the repair, replacement or 100 percent reimbursement at current prices without depreciation for any goods damaged or lost during transport for a sum up to $ 50,000.

Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.