Specialty Freight Services, Inc. v. Morris Trans Corp
3:24-cv-00672
M.D. Penn.Mar 11, 2025Background
- Specialty Freight Services, Inc. (SFS), as assignee of J&J Snack Foods, sued Morris Trans Corp. for shipment damage after a load of frozen snack foods thawed in transit and was rejected by the consignee.
- SFS, a federally-licensed property broker, alleged Morris (a federally-licensed motor carrier) breached an agreement to safely transport 26 pallets of frozen goods.
- SFS sought recovery under the Carmack Amendment, for breach of contract, and for negligence, claiming over $62,000 in damages and fees.
- Morris never appeared or responded, leading SFS to seek default judgment.
- The court was presented with various shipping records, bills of lading, and what SFS described as a load-rate confirmation but not a duly signed broker-carrier agreement.
- The court previously ordered SFS to provide a complete, signed contract, but SFS only resubmitted a blank template, claiming the original was not saved.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Carmack Amendment liability | SFS alleges Morris is liable as a carrier for loss/damage per federal law | No response | No liability; SFS was not on bills of lading, and no contractual nexus established |
| Breach of contract | SFS claims there was a contract requiring safe transit, which was breached | No response | No liability; no duly executed contract presented with binding terms |
| Negligence | SFS claims Morris failed its contractual duties, causing loss | No response | No liability; no evidence of a duty owed without a valid contract |
| Default judgment standard | SFS argues for default judgment due to Morris’s failure to respond | No response | Default judgment denied as claims lack sufficient legal basis |
Key Cases Cited
- Chamberlain v. Giampapa, 210 F.3d 154 (3d Cir. 2000) (establishes default judgment factors: prejudice, defense, culpability)
- Paper Magic Grp., Inc. v. J.B. Hunt Transp., Inc., 318 F.3d 458 (3d Cir. 2003) (Carmack Amendment governs carrier liability via bills of lading)
- Am. Eagle Outfitters v. Lyle & Scott Ltd., 584 F.3d 575 (3d Cir. 2009) (enforceable contracts require certainty and agreement on material terms)
- Texas & Pacific Ry. Co. v. Reiss, 183 U.S. 621 (1902) (bills of lading as transportation contracts subject to general rules of construction)
- Key Consol. 2000, Inc. v. Troost, 432 F. Supp. 2d 484 (M.D. Pa. 2006) (elements of breach of contract under Pennsylvania law)