Sacramento Navigation Co. v. Salz

273 U.S. 326, 47 S.Ct. 368, 71 L.Ed. 663, 1927 AMC 397 (1927)

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Sacramento Navigation Co. v. Salz

United States Supreme Court
273 U.S. 326, 47 S.Ct. 368, 71 L.Ed. 663, 1927 AMC 397 (1927)

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Facts

Sacramento Navigation Co. (defendant) operated as a shipping carrier on the Sacramento River in California. Sacramento Navigation transported goods on its nonmotorized barge, which was towed by its steamship. Salz (plaintiff) contracted with Sacramento Navigation to move Salz’s barley on Sacramento Navigation’s barge. While the barge was loaded with Salz’s barley and being towed by the steamer, the barge was in a collision with another vessel and was swamped. The collision was caused by the negligence of the steamer towing the barge. All of Salz’s barley was lost. Salz sued Sacramento Navigation for the loss. Sacramento Navigation contended that a statutory limitation on a carrier’s liability for damages that occur as a result of navigation errors applied to both the barge and the steamer towing the barge and that therefore Sacramento Navigation was not liable. Salz alleged that the contract for moving the goods only incorporated the services of the barge and that therefore the liability limitation did not apply to losses caused by the negligence of the steamer. The district court held for Salz, and the appeals court affirmed the ruling. Sacramento Navigation appealed to the Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Sutherland, J.)

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