Chesapeake & Ohio Railway v. Martin
United States Supreme Court
283 U.S. 209 (1931)
Chesapeake & Ohio Railway (Chesapeake) (defendant) agreed to ship a load of potatoes from Michigan to Virginia for Martin (plaintiff). Under the bill of lading, any claim for loss had to be brought within six months “after a reasonable time for delivery.” The potatoes were delivered to the wrong warehouse six days after shipment and had spoiled by the time Martin found them. Six months and 20 days after the shipment, Martin sued Chesapeake in Virginia court. At trial, a Chesapeake employee testified that a reasonable time for shipment would be eight days. The employee was not cross-examined on the issue, and no evidence was offered to refute the assertion. Chesapeake demurred, which is the same as a motion for a directed verdict under Virginia law. The demurrer was overruled, and a jury verdict was returned in favor of Martin. The appellate court affirmed. Chesapeake petitioned the United States Supreme Court for certiorari, which was granted to consider the federal question involving the bill of lading under the Interstate Commerce Act.
Rule of Law
Holding and Reasoning (Sutherland, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 159,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,700 briefs, keyed to 186 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.