Woodruff v. Atlas Van Lines, Inc.

Background

Matt Childers accepted a job with Meta, Inc., formerly Facebook, Inc., in Redmond, Washington. At the time, Childers and Katie Woodruff resided in Tiburon, California. Meta provided the plaintiffs with a paid relocation package.

The defendants packed and loaded the plaintiffs’ household goods in California and agreed to deliver them to Washington. The truck carrying the belongings caught fire while traveling to Washington, and the items on board were treated as a total loss. The plaintiffs alleged that the replacement value of the lost items was $302,577.11.

The plaintiffs filed suit in Marin County Superior Court, asserting four claims: breach of contract; negligence; strict liability under 49 U.S.C. § 14706; and breach of the duty of good faith and fair dealing. The defendants removed the case to federal court and moved to dismiss Counts 1, 2, and 4. The plaintiffs filed a statement indicating that they did not oppose the motion.

Legal issue

The defendants argued that the Carmack Amendment, 49 U.S.C. § 14706, provides the exclusive cause of action for the plaintiffs’ claims. The court explained that the Carmack Amendment is the exclusive remedy for contract claims involving delay, loss, failure to deliver, or damage to property. Relying on Ninth Circuit precedent, the court also concluded that this preemption extends to negligence claims and that the Amendment provides a complete defense to common-law claims alleging these types of harms.

Ruling

The court granted the defendants’ unopposed motion to dismiss Counts 1, 2, and 4. The court also vacated the scheduled hearing and stated that the order disposed of the motion at Docket No. 4. The opinion does not state a disposition for Count 3, the strict-liability claim under 49 U.S.C. § 14706.