Robert Blackmon v. International Van Lines, Inc.

Summary

The United States District Court for the District of Maryland considered a motion to dismiss claims arising from the interstate shipment of household goods. The court held that forum-selection clauses requiring litigation in Florida were contractually invalid because they conflicted with the Carmack Amendment's venue protections for household-goods shippers. The court denied dismissal of the Carmack Amendment claim but dismissed the state-law claims as preempted and dismissed the freestanding claim for injunctive relief.

Holdings

1. The forum-selection clauses were contractually invalid as applied to the interstate household-goods shipment because they violated public policy embodied in the Carmack Amendment's special venue provisions.
2. The theories alleging unlawful storage fees and retention of the goods were preempted by the Carmack Amendment.
3. Even assuming the misrepresentation and fraudulent-inducement theories were not preempted by the Carmack Amendment, they were preempted by the ICCTA because they related to the price, route, or service of a motor carrier.
4. A freestanding claim seeking injunctive relief fails because an injunction is a form of relief rather than an independent cause of action.

Questions Presented

1. Whether the forum-selection clauses requiring litigation in Florida were enforceable against Blackmon's Carmack Amendment claim.
2. Whether the Florida deceptive-trade-practices and common-law fraud claims were preempted by the Carmack Amendment or the Interstate Commerce Commission Termination Act.
3. Whether a freestanding claim for injunctive relief stated a cognizable cause of action.

Disposition

other