Carriers as such are bound to exercise ordinary diligence. Common carriers as such are bound to use extraordinary diligence, and in cases of loss the presumption of law is against them, and no excuse avails them unless the loss was occasioned by the act of God or the public enemies of the state.
(Orig. Code 1863, §§ 2038, 2039; Code 1868, §§ 2039, 2040; Code 1873, §§ 2065, 2066; Code 1882, §§ 2065, 2066; Civil Code 1895, §§ 2263, 2264; Civil Code 1910, §§ 2711, 2712; Code 1933, § 18-102.)
Cross references.- Standard of care for carriers who issue bills of lading, § 11-7-309.
Law reviews.- For annual survey on law of torts, see 43 Mercer L. Rev. 395 (1991).
JUDICIAL DECISIONSANALYSIS
General Considerations
Federal preemption.
- The Carmack Amendment to the Interstate Commerce Act, 49 U.S.C. § 11707(a)(1), preempts state law remedies against common carriers for negligent loss or damages to goods shipped under a lawful bill of lading. Joseph Land & Co. v. Christopher Edwards Cos., 211 Ga. App. 597, 440 S.E.2d 234 (1993).
"Extraordinary diligence" defined.
- Extraordinary diligence is defined as that extreme care and caution which very prudent and thoughtful persons use under like circumstances. Richmond & D.R.R. v. White & Co., 88 Ga. 805, 15 S.E. 802 (1892); Atlanta & W.P.R.R. v. Jacobs' Pharmacy Co., 135 Ga. 113, 68 S.E. 1039 (1910).
Rule of extraordinary diligence imposed upon common carriers by former Civil Code 1895, §§ 2263 and 2264 (see O.C.G.A § 46-9-1), required the exercise of that degree of diligence to avoid needlessly exposing goods to injury or destruction by an unforseen act of God, such as an extraordinary flood or freshet, and also to protect and preserve the goods after the peril became apparent. Richmond & D.R.R. v. White & Co., 88 Ga. 805, 15 S.E. 802 (1892).
"Loss" construed.
- "Loss," as used in former Code 1882, §§ 2065 and 2066 (see O.C.G.A § 46-9-1), included injury or damage to the goods. Central R.R. v. Hasselkus & Stewart, 91 Ga. 382, 17 S.E. 838, 44 Am. St. R. 37 (1892).
Common carrier distinguished from ordinary carrier.
- A carrier was bound to exercise ordinary diligence while a common carrier was bound to use extraordinary diligence under former Civil Code 1910, §§ 2711 and 2712 (see O.C.G.A § 46-9-1). Western & A.R.R. v. Waldrip, 18 Ga. App. 263, 89 S.E. 346 (1916).
Private carrier held to ordinary diligence.
- Person undertaking to transport goods as private carrier and not as a common carrier is bound only to ordinary diligence. Bloomberg-Michael Furn. Co. v. Urquhart, 38 Ga. App. 304, 143 S.E. 789 (1928).
Private carrier is liable for willful tort of its servant.
- A carrier is absolutely liable for the willful tort of its servant against a passenger, even where the carrier was a private carrier and was thus held only to the duty of reasonable care for the passenger's protection against the carrier's negligence. Bricks v. Metro Ambulance Serv., Inc., 177 Ga. App. 62, 338 S.E.2d 438 (1985).
Common carrier's absolute liability as insurer.
- Law fixes upon common carrier absolute liability as insurer, from which it may free itself only by showing that the loss or damage was occasioned by "the act of God or the public enemies of the state." Seaboard Air Line R.R. v. Henry Chanin Corp., 84 Ga. App. 442, 66 S.E.2d 113 (1951).
Carrier of passengers to exercise extraordinary care for passenger's safety.
- While carrier of passengers is not insurer in sense as common carrier of goods, the carrier is bound to exercise extraordinary care and diligence for the safety of the carrier's passengers, and it matters not the kind of conveyance used or the nature of the motive power employed. Sheffield v. Lovering, 51 Ga. App. 353, 180 S.E. 523 (1935).
Rule requiring exercise of extraordinary care applicable to partial loss.
- The rule under former Civil Code 1910, §§ 2711 and 2712 (see O.C.G.A § 46-9-1) which placed upon a common carrier the burden of showing the exercise of extraordinary diligence in the transportation of goods applied not only in cases of total loss, but also in case of partial loss by injury or damage to the goods from delay in transportation or delivery, and required that extraordinary diligence shall be shown as to the time of completing this service. Southern Cotton-Oil Co. v. Louisville & N.R.R., 15 Ga. App. 751, 84 S.E. 198 (1915).
General grounds of common carrier's liability.
- When a carrier fails to deliver the goods intrusted to the carrier's care, or delivers them in a damaged condition, no excuse avails the carrier, unless it was occasioned by the act of God, the public enemy, an inherent vice or natural deterioration of the object carried, or, in case of livestock, the viciousness of the animals, or that the carrier is excused by special contract made with the shipper, by statute, or by negligence of the shipper. Hines v. Vann, 26 Ga. App. 704, 106 S.E. 921 (1921).
Goods seized under legal process.
- If goods are seized and taken from the carrier's possession under legal process, its liability ceases. Savannah, G. & N.A.R.R. v. Wilcox, Gibbs & Co., 48 Ga. 432 (1873).
If delivery by the carrier has been prevented and rendered impossible by the seizure of the shipment in the enforcement by properly constituted legal officials of existing laws, the carrier is bound not to violate the law by making delivery of the goods which have been seized by properly authorized officers. Central of Ga. Ry. v. Evans, 172 Ga. 53, 157 S.E. 313 (1931).
Cited in Cooper v. Raleigh & G.R.R., 110 Ga. 659, 36 S.E. 240 (1900); Coweta County v. Central of Ga. Ry., 4 Ga. App. 94, 60 S.E. 1018 (1908); Central of Ga. Ry. v. Council Bros., 36 Ga. App. 573, 137 S.E. 569 (1927); Southern Ry. v. Atlantic Ice & Coal Co., 40 Ga. App. 103, 149 S.E. 71 (1929); Atlantic Coast Line R.R. v. South Ga. Milling Co., 44 Ga. App. 316, 161 S.E. 282 (1931); Atlantic C.L.R.R. v. Tifton Produce Co., 56 Ga. App. 776, 194 S.E. 72 (1937); Powell v. First Nat'l Bank, 58 Ga. App. 648, 199 S.E. 668 (1938); A.A.A. Hwy. Express, Inc. v. Bone & Hendrix, 69 Ga. App. 763, 26 S.E.2d 658 (1943); Seaboard Air Line R.R. v. Henry Chanin Corp., 84 Ga. App. 442, 66 S.E.2d 113 (1951); Darlington Corp. v. Finch, 113 Ga. App. 825, 149 S.E.2d 861 (1966); Atlanta Transit Sys. v. Hines, 138 Ga. App. 746, 227 S.E.2d 489 (1976); Axcan Scandipharm v. Schwan's Home Serv., 299 Ga. App. 49, 681 S.E.2d 631 (2009).
Acts of God
"Act of God" distinguished from unavoidable accident.
- There is, doubtless, a distinction between an act of God and an unavoidable accident. The former covers only natural accidents, such as lightning, earthquakes, tempests, and the like, and not accidents arising from the negligence or act of man. Harmony Grove Tel. Co. v. Potts, 24 Ga. App. 178, 100 S.E. 236 (1919).
"Act of God" includes unavoidable accidents.
- For decisions holding that "act of God" includes unavoidable accidents, see Fish v. Chapman & Ross, 2 Ga. 349 (1847); Central of Ga. Ry. v. Council Bros., 36 Ga. App. 573, 137 S.E. 569, cert. denied, 36 Ga. App. 825, S.E. (1927).
Carrier utilizing act of God exception.
- In order for carrier to avail oneself of act of God exception, the carrier must establish not only that the act of God ultimately occasioned the loss, but that the carrier's own negligence did not contribute thereto. Loo-Mac Freight Lines v. American Type Founders, Inc., 100 Ga. App. 203, 110 S.E.2d 566 (1959).
Carrier as Insurer
Conditions precedent to common carrier's liability.
- The liability of the common carrier in case of loss, for which there is no excuse unless the loss was occasioned by the act of God or the public enemies of the state, exists only, in the absence of an express or implied contract to the contrary, when the carrier is in complete possession and control of the goods for immediate shipment with nothing remaining to be done by the shipper to complete the consignment to the shipper for the purpose of carriage, and only until the goods are delivered to their destination and notice given to the consignee. Bell v. Fitz, 78 Ga. App. 28, 50 S.E.2d 241 (1948).
Point at which common carrier's responsibility as insurer commences.
- Responsibility of common carrier as insurer under former Code 1933, § 18-102 (see O.C.G.A § 46-9-1) commenced where there has been a complete delivery for the purpose of immediate transportation. Bell v. Fitz, 78 Ga. App. 28, 50 S.E.2d 241 (1948).
Liability of carrier where shipper requests delay of shipment.
- If shipment is delayed by request of shipper, liability of carrier is only that of warehouseman during such delay, and carrier cannot be charged with the loss of the goods if, while they were in the carrier's custody pending instruction from the shipper, the carrier exercised ordinary care. Bell v. Fitz, 78 Ga. App. 28, 50 S.E.2d 241 (1948).
Carrier liable only as warehouseman where goods stored only to accommodate shipper.
- If a common carrier receives goods into the carrier's own warehouse for the accommodation of oneself and one's customers, so that the deposit there is a mere accessory to the carriage and for the purpose of facilitating it, the carrier's liability as a carrier will commence with the receipt of the goods; but, on the contrary, if the goods when so deposited are not ready for immediate transportation, and the carrier cannot make arrangements for their carriage to the place of destination until something further is done, or some further direction is given or communication made concerning them by the owner, or consignor, the deposit must be considered to be in the meantime for the carrier's convenience and accommodation, and the receiver, until some change takes place, will be responsible only as a warehouseman. Bell v. Fitz, 78 Ga. App. 28, 50 S.E.2d 241 (1948).
Shipper seeking damages must show carelessness or negligence by carrier.- Shipper seeking to recover damages of common carrier must show some injury which cannot be the result of inherent nature or defects of goods shipped, or some carelessness or negligence on the part of the carrier likely to cause the injury, before the burden is cast on the carrier to show that the carrier is not in fault. Hussey v. Saragossa, 12 F. Cas. 1066 (S.D. Ga. 1876).
To make out case for damage to goods, the shipper need only show the delivery in good condition and the receipt in damaged condition; the carrier, to make good the carrier's defense must then show that the damage arose from causes unmixed with any negligence on the carrier's part. Loo-Mac Freight Lines v. American Type Founders, Inc., 100 Ga. App. 203, 110 S.E.2d 566 (1959); Empire Aluminum Corp. v. SS Korendijk, 391 F. Supp. 402 (S.D. Ga. 1973).
Establishing prima facie case against delivering carrier.- Prima facie case against delivering carrier is shown by alleging the delivery of the goods or merchandise shipped in good order to the initial carrier and receipt at the destination from the terminal carrier of the goods in a damaged condition. Empire Aluminum Corp. v. SS Korendijk, 391 F. Supp. 402 (S.D. Ga. 1973).
Ending responsibility as delivering carrier.
- Because the injured party was injured when a container that had held hazardous materials exploded, the carrier that had delivered the container hours earlier was not liable as an insurer under O.C.G.A. § 46-9-1, as the injured party was not an owner of the goods. Booth v. Quality Carriers, Inc., 276 Ga. App. 406, 623 S.E.2d 244 (2005).
Proof of receipt in good order and delivery in damaged condition shifts burden to carrier.- Proof of receipt in good order and delivery in damaged condition casts burden on common carrier of establishing an affirmative defense. Empire Aluminum Corp. v. SS Korendijk, 391 F. Supp. 402 (S.D. Ga. 1973).
Shipper must show receipt in good order where condition of goods not apparent.- Where real condition of goods is not apparent, carrier is not liable except upon a showing by shipper that they were in fact in good order when delivered. Empire Aluminum Corp. v. SS Korendijk, 391 F. Supp. 402 (S.D. Ga. 1973).
Presumption that goods received in good order.- Where it does not appear carrier received goods in bad order, presumption is that they were in good order. Empire Aluminum Corp. v. SS Korendijk, 391 F. Supp. 402 (S.D. Ga. 1973).
Presumption that goods received back by shipper are in good order.
- There is presumption that goods received are received back by shipper in good order when the contrary does not affirmatively appear. Loo-Mac Freight Lines v. American Type Founders, Inc., 100 Ga. App. 203, 110 S.E.2d 566 (1959).
Carrier not liable for theft of goods still in customers' exclusive control.
- Where customers' jewelry was never delivered to defendant, a moving company, for transportation, but remained in the exclusive control of the customers until the time of its theft, allegedly by the defendant's employee, the carrier did not owe its customers a duty of extraordinary diligence to protect the jewelry and is not absolutely liable to them for the alleged theft. Effort Enters., Inc. v. Crosta, 194 Ga. App. 666, 391 S.E.2d 477 (1990).
Last carrier presumed responsible for damage absent evidence to contrary.- In the absence of evidence locating the place of damage to goods in transit over several connecting lines, the presumption is that where goods are delivered to an initial carrier in good condition and are delivered by the terminal carrier in a damaged condition, that they were injured on the line of the last carrier, and the burden of proof is on the terminal carrier, when sued, to show that the damage was not done on its line. Empire Aluminum Corp. v. SS Korendijk, 391 F. Supp. 402 (S.D. Ga. 1973).
Contributory negligence of shipper.
- The presumption of liability raised by former Civil Code 1895, §§ 2263 and 2264 (see O.C.G.A § 46-9-1) may be rebutted, if it appeared that the injury was caused by the plaintiff personally, whether the act which caused the injury be due to negligence or design. In other words, the provisions of that section have no reference to a case where the loss was attributable, either in whole or in part, to the act of the shipper personally. Southern Ry. v. Morrison, 105 Ga. 543, 31 S.E. 564 (1898); Coweta County v. Central of Ga. Ry., 4 Ga. App. 94, 60 S.E. 1018 (1908).
Procedure and Pleadings
Distinction between intrastate and interstate shipments necessary for application of Code section.
- In applying former Code 1933, § 18-102 (see O.C.G.A § 46-9-1), distinction must be made between shipments intrastate and those interstate, in which latter case federal law superseded state law and fixed the provisions of the uniform bill of lading as the contract. Seaboard Air Line R.R. v. Henry Chanin Corp., 84 Ga. App. 442, 66 S.E.2d 113 (1951).
Carrier claiming negligence by shipper must show the carrier's own lack of fault.
- If a common carrier relies upon the defense that the loss was occasioned by the fault of the shipper or the shipper's agent, the carrier must bring oneself within the defense by negativing contributing fault on the carrier's own part. Bugg v. Perry & Faircloth, 42 Ga. App. 523, 156 S.E. 708 (1931).
Where it appears that the injury resulted solely from the fault of the shipper in improperly packing the merchandise the rule is that if the defendant defends on the ground that the shipper is guilty of negligence in improper packing, the burden is on the carrier not only to show that the loss was occasioned by such fault on the part of the shipper but the carrier must negative any contributing fault on the carrier's own part. Loo-Mac Freight Lines v. American Type Founders, Inc., 100 Ga. App. 203, 110 S.E.2d 566 (1959).
Carriers not liable for damages due to intrinsic qualities of goods carried.
- Injury from inherent qualities is somewhat in nature of damages resulting from act of God; and in the more recent development of the rules as to the liability of carriers it has been held that they are not liable for loss or damage due to the intrinsic qualities of the goods carried. Forrester v. Georgia R.R. & Banking, 92 Ga. 699, 19 S.E. 811 (1893); Susong v. Florida C. & P.R.R., 115 Ga. 361, 41 S.E. 566 (1902); Ohlen v. Atlanta & W.P.R.R., 2 Ga. App. 323, 58 S.E. 511 (1907); Capital City Oil Co. v. Central of Ga. Ry., 16 Ga. App. 750, 86 S.E. 57 (1915).
Carrier may assert defense of inherent defects in goods.
- The carrier's right of defense for a failure to deliver goods of a perishable nature entrusted to the carrier's care, or where the carrier delivered them in a damaged condition, has been so enlarged that the carrier may show that the damage was occasioned by an inherent vice or natural deterioration in the goods. Bugg v. Perry & Faircloth, 42 Ga. App. 523, 156 S.E. 708 (1931).
Carrier must show lack of negligence where inherent defect claimed as defense.
- When goods, though perishable or liable to rapidly deteriorate from internal causes, are damaged while in the hands of the carrier, the burden of proof is upon the carrier to show either that the carrier was free from negligence, or that notwithstanding the carrier's negligence the damage occurred without the carrier's fault; that is, that the carrier's negligence did not contribute to the damage. Central R.R. v. Hasselkus & Stewart, 91 Ga. 382, 17 S.E. 838, 44 Am. St. R. 37 (1892); Southern Express Co. v. Bailey, 7 Ga. App. 331, 66 S.E. 960 (1910).
There is a defense of inherent vice but the burden of establishing it is on the defendant and the defendant must affirmatively show that the damage resulted from such inherent vice unmixed with defendant's own negligence. Loo-Mac Freight Lines v. American Type Founders, Inc., 100 Ga. App. 203, 110 S.E.2d 566 (1959).
There is a defense of inherent vice but the burden of establishing it is on the defendant and defendant must affirmatively show that the damage resulted from such inherent vice unmixed with defendant's own negligence. Loo-Mac Freight Lines v. American Type Founders, Inc., 100 Ga. App. 203, 110 S.E.2d 566 (1959).
Carrier's duty to show bad condition of goods delivered.- It is carrier's duty to show that goods were in bad condition when delivered to the carrier. Empire Aluminum Corp. v. SS Korendijk, 391 F. Supp. 402 (S.D. Ga. 1973).
Carrier's duty to advise shipper as to transportation delays.
- Carrier has duty to advise shipper as to any cause likely to delay transportation of which it knows or has reason to know, and if it fails in its duty in this respect, a delay in the transportation of the goods will not be excused, and that too irrespective of the nature of the cause. Atlantic Coast Line R.R. v. South Ga. Milling Co., 44 Ga. App. 316, 161 S.E. 282 (1931).
Presumptions and burden of proof.
- In case of loss the presumption was against the carrier under former Civil Code 1895, §§ 2263 and 2264 (see O.C.G.A § 46-9-1). The burden, however, is on the plaintiff to show the loss; but for the purposes of a prima facie case this may be done by showing such circumstances as would create the inference against the defendant that the goods were lost; as, for instance, they were bailed to the carrier a sufficient length of time to be transported to destination and have not arrived there. Southern Ry. v. Montag, 1 Ga. App. 649, 57 S.E. 933 (1907).
Extraordinary negligence presents jury question.
- In determining what very prudent and thoughtful persons would do under certain circumstances, the situation and surrounding facts, including the existence of an emergency, if there was one, are to be considered by the jury. Richmond & D.R.R. v. White & Co., 88 Ga. 805, 15 S.E. 802 (1892); Atlanta & W.P.R.R. v. Jacobs' Pharmacy Co., 135 Ga. 113, 68 S.E. 1039 (1910).
RESEARCH REFERENCES
Am. Jur. 2d.
- 13 Am. Jur. 2d, Carriers, § 390 et seq.
C.J.S.- 13 C.J.S., Carriers, §§ 76, 77, 678.
ALR.
- Liability of carrier for injury due to casual or temporary condition of station or its approaches, 10 A.L.R. 259.
Car shortage as affecting liability of carrier for failure to furnish cars, 10 A.L.R. 342.
Liability of carrier for loss of, or damage to, freight by acts of mob or strikers, 20 A.L.R. 262.
Duty and liability of carrier of passengers for hire by automobile, 20 A.L.R. 914; 45 A.L.R. 297; 69 A.L.R. 980; 96 A.L.R. 727; 152 A.L.R. 1160.
State of weather as affecting liability for injury to one struck by train or street car, 20 A.L.R. 1064.
Res ipsa loquitur as applicable to injury to passenger in a collision where one of the vehicles is not within carrier's control, 25 A.L.R. 690; 83 A.L.R. 1163; 161 A.L.R. 1113.
Liability of carrier for injury to passenger by car door, 25 A.L.R. 1061, 41 A.L.R. 1089.
Duty of carrier to render special service to protect goods en route, as affected by the fact that it is not provided for by the published tariff, 32 A.L.R. 111.
Carrier's liability for injury to passenger due to rushing or crowding of passengers, 32 A.L.R. 1315; 155 A.L.R. 634.
Duty and liability of carrier as to money collected on c.o.d. shipment, 36 A.L.R. 464.
Liability of carrier for injury to passenger while passing through turnstile, door, or gate, 40 A.L.R. 828.
Liability of carrier for injury to passenger due to construction of floor of car or vessel on different levels, 48 A.L.R. 1424.
Wholesale or retail price as measure of damages against carrier for loss of goods, 50 A.L.R. 1467; 67 A.L.R. 1427.
Stipulation limiting amount of carrier's liability as applicable where goods are stolen by its employee, 52 A.L.R. 1073.
Duty and liability of carrier as to assisting passenger to board or alight from car or train, 55 A.L.R. 389; 59 A.L.R. 940.
Liability of street railway company for injury to passenger or pedestrian as result of overhang of car in rounding curve, 55 A.L.R. 479.
Duty and liability of carrier with respect to heating freight car, 55 A.L.R. 905.
Duty and liability of carrier to passenger attempting to leave moving street car, 56 A.L.R. 981.
Liability of proprietor or operator of private railroad for injury to one other than employee riding thereon, 57 A.L.R. 818.
Carrier's liability for injury to passenger by heating apparatus, 58 A.L.R. 692.
Liability of carrier by water for injury to passenger while embarking or disembarking, 59 A.L.R. 1355.
Duty and liability to passenger temporarily leaving train, 61 A.L.R. 403.
Status of, and liability of street railway company to, person approaching to board street car, 75 A.L.R. 285.
Liability of carrier operating in street to passenger struck by other vehicle while on platform, step, or running board of car, 77 A.L.R. 429.
Carrier's liability as affected by improper packing or preparation of goods for shipment, 81 A.L.R. 811.
Ferry operator's duty as regards automobiles or their occupants, 82 A.L.R. 798.
Assumption of risk and contributory negligence in connection with injuries arising from improper manner of loading or fastening load on freight car, 106 A.L.R. 1140.
Presumption and burden of proof as to carrier's responsibility for goods received in good condition and delivered to consignee in bad condition, 106 A.L.R. 1156.
Changed conditions as affecting duty, or enforcement of duty, as to train service or maintenance of stations imposed upon railroad by charter or statute, 111 A.L.R. 57.
Person or corporation transporting goods on the public highways as a common carrier, or private or contract carrier, as regards liability for loss of or damage to goods, 112 A.L.R. 89.
Liability of railroad company for injury to trespassers or licensees other than employees or passengers struck by object projecting, or thrown, from passing train, 112 A.L.R. 850.
Liability of carrier for injury to passenger as result of ice, snow, or rain on exposed or interior portions of car or vessel, 117 A.L.R. 522.
Liability of carrier responsible for passenger leaving train or car at station other than his destination for subsequent injury to or illness or death of passenger, 118 A.L.R. 1327.
Liability of motor carrier for personal injuries to or death of passenger due to structural conditions of interior of conveyance, 126 A.L.R. 461.
Liability of common carrier by motorbus or taxicab for personal injury to or death of passenger where condition of highway was the cause or a contributing factor, 126 A.L.R. 1084.
Liability of railroad for injury to or death of one other than its employee due to defective condition of car received from another railroad which he was unloading or loading, 126 A.L.R. 1095.
Carrier's liability for conduct of passenger (other than assault) causing injury to other passenger, 140 A.L.R. 1194.
Status, rights, and obligations of freight forwarders, 141 A.L.R. 919.
Liability of motorbus carrier for death of or injury to discharged passenger struck by vehicle not within its control, 145 A.L.R. 1206.
Carrier's liability for damage to goods during loading or unloading as affected by participation by consignor or consignee or their employees, 149 A.L.R. 644.
Liability of railroad company for negligence in extricating animal caught in tracks or trestle, 159 A.L.R. 152.
Ejection of passenger as ground of motorbus carrier's liability for subsequent injury or death, 165 A.L.R. 545.
Initial carrier's liability as that of carrier or of warehouseman in respect of goods while in its warehouse awaiting delivery to connecting carrier, 172 A.L.R. 802.
Carrier's liability to person in street or highway for purpose of boarding its vehicle, 7 A.L.R.2d 549.
Liability of carrier for injury to passenger due to improper lighting of vehicle, 8 A.L.R.2d 233.
Duty and liability of carrier to intoxicated passenger while en route, 17 A.L.R.2d 1085.
Contributory negligence of physically handicapped or intoxicated person in boarding or alighting from standing train or car, 30 A.L.R.2d 334.
Railroad carrier's liability for loss of baggage or effects accompanying passenger, 32 A.L.R.2d 630.
Carrier's liability to passenger injured by landslide, or the like, 34 A.L.R.2d 831.
Liability of carrier to one injured by article thrown from conveyance by passenger, 35 A.L.R.2d 788.
Carrier's duty and liability to its passenger injured on platform and the like of station or terminal owned by another company, 41 A.L.R.2d 1286.
Liability of motor carrier for injury to passenger's hand in vehicle door, 42 A.L.R.2d 1190.
Liability of carrier by land or air for damage to goods shipped resulting from improper loading, 44 A.L.R.2d 993.
Liability of carrier to passenger injured by hurling of object through window by a third person, 46 A.L.R.2d 1098.
Carrier's liability to passenger injured while using washroom or lavatory facilities on conveyance, 50 A.L.R.2d 1071.
Employer's liability for assault by taxicab or motorbus driver, 53 A.L.R.2d 720.
Motor carrier's liability for injury to passenger by sudden stopping, starting, or lurching of conveyance, 57 A.L.R.2d 5.
Liability of air carrier to passenger injured while boarding or alighting, 61 A.L.R.2d 1113.
Liability to patron of scenic railway, roller coaster, or miniature railway, 66 A.L.R.2d 689.
Liability of carrier by air for injury or death of passenger due to downdraft, updraft, or turbulence, 73 A.L.R.2d 379.
Liability of motor carrier for loss of passenger's baggage or packages, 68 A.L.R.2d 1350.
Railroad's liability for injury or death of one other than employee because of alleged unsafe or defective condition of its own freight car which he was loading or unloading, 99 A.L.R.2d 176.
Shipper's misdescription of goods as affecting carrier's liability for loss or damage, 1 A.L.R.3d 736.
Railroad carrier's liability where goods were allegedly damaged by failure to properly refrigerate, 4 A.L.R.3d 994.
Liability of carrier by land for damage to goods resulting from improper packing by carrier, 7 A.L.R.3d 723.
Liability for damage to highway or bridge caused by size or weight of motor vehicle or load, 53 A.L.R.3d 1035, 31 A.L.R.5th 171.
Carrier's liability for injury or death of infant passenger as affected by fact that child was in custody of parent or other adult, 74 A.L.R.3d 1171.
Carrier's liability based on serving intoxicants to passenger, 76 A.L.R.3d 1218.
Liability of taxicab carrier to passenger injured while alighting from taxi, 98 A.L.R.3d 822.
Liability of common carrier for personal injury or death of passenger occasioned by inhalation of gases or fumes from exhaust, 99 A.L.R.3d 751.
Liability for injury on, or in connection with, escalator, 1 A.L.R.4th 144.
Liability of motorbus carrier to passenger injured through fall while alighting at place other than regular bus stop, 7 A.L.R.4th 1031.
Liability of land carrier to passenger who becomes victim of third party's assault on or about carrier's vehicle or premises, 34 A.L.R.4th 1054.
Liability of land carrier to passenger who becomes victim of another passenger's assault, 43 A.L.R.4th 189.
Liability of operator of ambulance service for personal injuries to person being transported, 68 A.L.R.4th 14.
Incidental provision of transportation services, by party not primarily in that business, as common carriage subject to state regulatory control, 87 A.L.R.4th 638.
Release of one joint tortfeasor as discharging liability of others under Uniform Contribution Among Tortfeasors Act and other statutes expressly governing effect of release, 6 A.L.R.5th 883.
Liability of motorbus carrier or driver for death of, or injury to, discharged passenger struck by other vehicle, 16 A.L.R.5th 1.
Liability of owner or operator of shopping center, or business housed therein, for injury to patron on premises from criminal attack by third party, 31 A.L.R.5th 550.
Limitation of liability of air carrier for personal injury or death, 91 A.L.R. Fed. 547.