Southern Furniture Leasing v. YRC, 989 F.3d 1141

YRC is a less‑than‑truckload (LTL) carrier that uses standard two‑page bills of lading where customers provide estimated shipment weight (weight is “subject to correction”).
Industry practice is to reweigh shipments and adjust charges up or down; beginning in Sept. 2005 YRC allegedly stopped issuing downward (negative) reweigh corrections while still issuing upward corrections, without notifying customers.
Southern Furniture learned of the alleged ongoing overcharging only after a DOJ‑unsealed qui tam complaint in Dec. 2018 and filed a putative class action in March 2019 asserting breach of contract, breach of good faith, unjust enrichment, and deceptive trade practices.
YRC moved to dismiss, arguing among other things that 49 U.S.C. § 13710(a)(3)(B) bars challenges not made within 180 days of receipt of the bill; the district court dismissed under that provision and declined to reach other defenses.
The Tenth Circuit affirmed: it held Southern Furniture has Article III standing, § 13710(a)(3)(B)’s 180‑day requirement applies to court actions (not only STB proceedings), Southern Furniture qualifies as a "shipper," and the complaint presents a contest of charges subject to the 180‑day rule.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing	Southern Furniture alleged it paid inflated charges and thus suffered concrete injury.	YRC argued allegations were too vague to show injury in fact.	Plaintiff has Article III standing; allegations sufficiently pleaded.
Applicability of §13710(a)(3)(B) to court suits	The 180‑day rule applies only to proceedings before the STB, not court actions.	The statute’s plain text imposes a 180‑day condition to contest charges generally, not limited to STB.	§13710(a)(3)(B) applies to contests in court as well as before the STB.
Whether Southern Furniture is a “shipper”	Southern Furniture argued it is not an "individual shipper" under ICCTA definitions and thus §13710(a)(3)(B) doesn’t apply.	YRC: Southern Furniture contracted for transport and fits the ordinary meaning of "shipper."	Court treated "shipper" by ordinary meaning; Southern Furniture is a shipper under §13710(a)(3)(B).
Whether the complaint alleges a "billing dispute"	Plaintiff contended its claims (fraud, overcharging scheme) are broader than a mere billing contest.	YRC argued plaintiff is challenging billed charges—the paradigmatic "contest."	The complaint challenges billed charges and thus is a billing dispute subject to the 180‑day notice requirement.

Spokeo v. Robins, 136 S. Ct. 1540 (2016) (injury‑in‑fact and standing pleading standards)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requirements)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards and plausibility)
In re Taylor, 737 F.3d 670 (10th Cir. 2013) (statutory interpretation principles)
Bostock v. Clayton Cty., 140 S. Ct. 1731 (2020) (textualist construction guidance)
Skidmore v. Swift & Co., 323 U.S. 134 (1944) (weight of agency interpretations under Skidmore)
United States v. Mead Corp., 533 U.S. 218 (2001) (limits on applying Chevron deference)
Chevron U.S.A., Inc. v. Natural Res. Def. Council, 467 U.S. 837 (1984) (agency deference framework)
Powerex Corp. v. Reliant Energy Servs., 551 U.S. 224 (2007) (same‑term usage across a statute)
Roberts v. Sea‑Land Servs., 566 U.S. 93 (2012) (read statutory language in context)