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Puerto Rico Maritime Shipping Authority v. Crowley Towing and Transportation Company, Third-Party v. State Fair Production, Inc., Third-Party Puerto Rico Maritime Shipping Authority v. Crowley Towing and Transportation Company, Third-Party v. State Fair Production, Inc., Third-Party
Citations: 747 F.2d 803; 1987 A.M.C. 911; 1984 U.S. App. LEXIS 17046Docket: 84-1092
Court: Court of Appeals for the First Circuit; November 1, 1984; Federal Appellate Court
The case involves the Puerto Rico Maritime Shipping Authority (Navieras) leasing eleven intermodal trailers to State Fair for transportation between the continental U.S. and Puerto Rico. When Navieras learned of State Fair's intention to ship the carnival to Venezuela, it warned State Fair not to use the trailers, but the warning was disregarded. State Fair packed the carnival into over one hundred trailers, including Navieras' eleven, and hired Crowley Towing and Transportation Company to ship them. Following the shipment, the carnival encountered legal issues in Venezuela, resulting in the seizure of the trailers, which remain in Venezuela. Navieras sued Crowley for wrongfully transporting the trailers to Venezuela. The district court ruled in favor of Crowley after a two-day bench trial. Navieras appealed, arguing that Crowley should be held liable under Puerto Rico Civil Code section 1802, which addresses damages caused by fault or negligence. The court focused on whether Crowley knew or should have known that the trailers were not authorized for shipment to Venezuela. The district court found that Crowley was unaware of any shipping permission issues when State Fair delivered the carnival and had no obligation to investigate further. Navieras contested this finding as "clearly erroneous," but the appellate court reviewed the record and upheld the district court's decision, noting that common carriers are generally not required to verify ownership of shipped goods unless special circumstances warrant further inquiry. The judgment emphasized the reasonable assumption that a carrier can make regarding the authority of the party shipping goods. Navieras contends that Crowley's vice president, Capt. William Coleman, observed trailers with logos from leasing companies Sea-land and Chessy System during the loading process and subsequently drafted an indemnity letter to shift liability to State Fair for any issues arising from Crowley shipping trailers not owned by State Fair. Navieras argues that Coleman's concern warranted further inquiry into the trailers' ownership. However, Coleman's testimony suggests that his concern was primarily about the potential inability of Venezuelan carriers to return the trailers to Puerto Rico, and not about State Fair's authority to ship them. The district court interpreted Coleman’s motivations as only weakly related to the question of negligence, supporting its finding of no negligence on Crowley's part, which precludes liability under Civil Code Sec. 1802. Additionally, Navieras claimed Crowley should be liable for unjust enrichment under Puerto Rico Civil Code Sec. 1787, but the court found no evidence of Crowley's enrichment or unjust conduct, noting that Navieras had not acted to prevent the trailers' shipment. Furthermore, Navieras did not include the unjust enrichment claim in its complaint, rendering it not properly before the court. Crowley’s cross-appeal for attorney's fees was denied, as the district court found Navieras was not obstinate in its claims, and the issues raised were not frivolous. The judgment of the district court was affirmed.