Laufer Group International, Ltd. v. Standard Furniture Mfg. Co., LLC

Background

Laufer Group International, Ltd. is a non-vessel operating common carrier that arranges transportation through steamship lines. In May 2018, Laufer and Standard Furniture Manufacturing Co., LLC entered into a service arrangement covering Standard’s shipments. International Furniture Marketing LLC was listed as eligible to book cargo under the arrangement. Todd Evans and Dan Siggers were Standard’s CEO and President and Chief Operating Officer, respectively, during the relevant period.

Laufer issued bills of lading for the shipments and invoices for freight and additional charges. The additional charges included fees for delays in picking up containers, returning empty containers, storage, and chassis use. The disputed charges covered December 12, 2018, through February 10, 2020, and totaled $517,531.94 plus interest, according to the opinion. Laufer moved for summary judgment, which asks whether the evidence leaves any genuine dispute over facts that could affect the result.

Contract documents and liability

The court held that the parties’ service arrangement was unambiguous. It determined that the relevant documents establishing the parties’ obligations were the arrangement, tariff LUFR-006, the bills of lading and their terms and conditions, and Laufer’s essential terms tariff. The court rejected the defendants’ argument that separate standard operating procedures controlled, reasoning that the arrangement did not make those procedures binding and that the procedures were digitally signed only by Standard.

The defendants argued that Laufer had failed to meet obligations concerning delivery and container pickup times, Macy’s appointments, notice and approval requirements, billing, add-on invoices, and shipment documentation. The court concluded that these alleged obligations were not contained in the governing contractual documents. It also relied on the bills of lading’ provision stating that Laufer did not guarantee delivery at a particular time and was not liable for losses caused by delay. The court therefore rejected arguments that Laufer breached the agreement by late appointments or late pickup and delivery, or that Laufer was responsible for accessorial charges caused by tariff-related congestion.

The court also found no genuine dispute about whether Laufer’s PeerPLUS system provided enough information to support the accessorial charges. The court noted evidence that the system included in-gate and out-gate information and that the defendants had not shown how that information differed from the interchange documentation they claimed was required. The court concluded that there was no genuine dispute about liability. In a footnote, it also rejected an argument that International Furniture Marketing LLC or the individual defendants were not liable for the charges.

Damages and disposition

The court rejected the defendants’ contention that Laufer’s invoices were facially suspect. It explained that the disputed “terminal return date” referred to delivery of the loaded container to a terminal in Asia, not the return of empty containers to a United States port.

The court nevertheless found a limited factual dispute about damages. The service arrangement allowed additional cargo to be shipped under the same terms and conditions if Laufer could accommodate it. Laufer argued that cargo exceeding the required 600 containers was subject to market rates, while the defendants argued that market-rate shipments required Standard’s written consent. The court found that the evidence, including the parties’ emails, did not resolve whether the remaining freight invoices should be charged at market or fixed rates.

Judge J. Paul Oetken granted in part and denied in part Laufer’s motion for summary judgment. The ruling resolved liability in Laufer’s favor but left the limited rate-related damages question for the remaining phase of the case. The parties were directed to submit a letter within 21 days proposing trial dates and length and addressing possible settlement discussions. The clerk was directed to close the summary-judgment motion.