Carrier Services Group, Inc. v. Schneider Logistics, Inc., 4:15-cv-02626

Carrier Services Group bought 38 used telecommunications equipment towers from ATS for $25,000 and hired Schneider Logistics to arrange transport; Rowland was brokered to carry 25 of those towers.
Rowland picked up the 25 towers on August 4, 2015, accompanied by a clean bill of lading; Rowland drivers have a company "no-touch" policy and did not assist with loading.
On delivery to Carrier's Ohio warehouse on August 6, 2015, five of the 25 towers were noted on the bill of lading as fallen and damaged; Carrier's CEO later declared the entire 25-piece load to be "scrap."
Carrier did not test any equipment or produce objective valuation evidence; photographic evidence and the bill of lading showed only five fallen units and 20 apparently intact units.
Carrier sued under the Carmack Amendment (49 U.S.C. §14706). Rowland moved for summary judgment arguing Carrier failed to establish a prima facie Carmack claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Carrier prove initial receipt in good condition?	Clean bill of lading and ATS supervisor affidavit show towers were undamaged at pickup.	Rowland: "no-touch" policy and hidden internal components mean carrier lacked opportunity to inspect; carrier can't rely on bill for unseen parts.	Held for Carrier: clean bill of lading and evidence of visibility of towers establish initial good condition.
Did Carrier prove loss or damage to the shipment?	Carrier: all 25 pieces were damaged (CEO testimony); entire load was "scrap."	Rowland: only five pieces were noted as fallen; photographs and lack of testing undermine claim of total loss.	Split: Carrier proved damage to the five fallen towers but failed to prove damage to the remaining 20.
Did Carrier prove amount of actual loss/damages?	Carrier seeks >$160,000 relying on claimed resale value and lost future sales.	Rowland: Carrier provided no testing, invoices, or objective valuation; lost profits speculative.	Held for Rowland as to excess damages: Carrier cannot recover beyond proof; no admissible evidence supports damages beyond the five damaged units' actual loss.
Do any Carmack exceptions excuse Rowland's liability?	Carrier: N/A (no exception argued).	Rowland: alleged lack of opportunity to inspect, suggesting non-liability.	Held for Carrier: Rowland failed to raise a statutory Carmack exception; liability stands for the proven damaged units.

Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (drawing inferences on summary judgment)
Missouri Pac. R.R. v. Elmore & Stahl, 377 U.S. 134 (Carmack exceptions)
Southern Pacific Transportation Co. v. Commercial Metals Co., 456 U.S. 336 (bill of lading as contract)
CNA Ins. Co. v. Hyundai Merchant Marine Co., 747 F.3d 339 (Carmack prima facie elements; low evidentiary threshold)
Sec. Ins. Co. v. Old Dominion Freight Line, Inc., 391 F.3d 77 (clean bill of lading effect when inspection possible)
Allied Tube & Conduit Corp. v. Southern Pacific Transportation Co., 211 F.3d 367 (sampling/testing to establish damage to whole shipment)
Camar Corp. v. Preston Trucking Co., 221 F.3d 271 (measuring actual loss under Carmack)