Williams v. North American Van Lines of Texas, Inc., 731 F.3d 367

In July 2010 Williams contracted with North American Van Lines to ship household goods from New York City to Austin; delivery was late and many items were severely damaged or lost.
Williams’ counsel sent initial notice and later letters (Jan. & Apr. 2011) demanding $182,750 (including $170,000 for repair/replacement, $10,000 mental anguish, $2,750 attorney fees); an original claim form listed damaged items but did not provide itemized monetary values.
North American offered under $17,000, disputed some damage and contended many values were unprovable; carrier relied on third‑party restoration estimates for its offer.
Williams sued in state court; North American removed under the Carmack Amendment and moved for summary judgment arguing Williams’ written claim failed the Department of Transportation regulation (49 C.F.R. §1005.2(b)) because it did not state a specified or determinable amount.
The district court granted summary judgment for North American, concluding (1) Williams’ demand was an “estimate” and not a specified amount and (2) she failed to list individual item values.
The Fifth Circuit reversed: Williams’ letters requested a specific total ($182,750 and $170,000 for repair/replacement) and the regulation does not require an itemized valuation at filing; remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the written claim satisfied 49 C.F.R. §1005.2(b)’s requirement of a “specified or determinable amount”	Williams: letters demanded a specific total ($182,750; $170,000 repair/replacement), satisfying the requirement	North American: amounts were mere estimates and not a specified/determinable sum; original form lacked item values	Held: Specific total demand suffices; Williams met §1005.2(b) because she requested an exact amount
Whether an estimate of total damages is inadequate under §1005.2(b)	Williams: a total based on estimates still constitutes a specified claim when a precise dollar figure is stated	North American: an “estimate” does not give the carrier adequate notice of liability	Held: The fact the total was based on estimates does not render it unspecified; stating an exact amount is adequate
Whether an itemized valuation of individual components is required at filing	Williams: itemization is not required; alternatively, a claim is "determinable" by later calculation	North American: failure to list individual values means claim is not specified/determinable	Held: Regulation requires either a specified total or an amount determinable from itemization; it does not mandate both or require itemization at initial filing

Templet v. HydroChem Inc., 367 F.3d 473 (5th Cir. 2004) (standard of review for summary judgment and de novo review after Rule 59(e) materials considered)
Salzstein v. Bekins Van Lines Inc., 993 F.2d 1187 (5th Cir. 1993) (claim for an estimated total amount can be sufficient to meet regulatory notice requirements)