Plaintiff Miami Warehouse Logistics Inc (MWL), a logistics company, hired defendant Seaboard Marine Ltd (Seaboard), an ocean transport company, to ship 35 drums of cranberry concentrate from the United States to the Dominican Republic. During the shipment, the concentrate had not been carried at the correct temperature and was spoiled. Thus, MWL filed a claim against Seaboard seeking compensatory damages under state law for breach of contract and negligence. Seaboard denied the claim and moved for summary judgment arguing that: 1) federal law in the form of COGSA/the Hague Rules pre-empted MWL’s claims, and 2) MWL’s claims were time-barred under COGSA/the Hague Rules.

Held: Defendant’s motion for summary judgment was granted. The court explained that claims made pursuant to a bill of lading pre-empted state-law causes of action, and therefore, COGSA/the Hague Rules applied in this case. In addition, the court held that, since MWL served Seaboard after the expiry of the one-year COGSA/Hague Rules limitations period, it was precluded from bringing any claim against Seaboard. Notwithstanding, MWL argued that COGSA/the Hague Rules did not apply because Seaboard deviated from the bill of lading by not shipping the concentrate at the correct temperature, but the court held that the doctrine of deviation is generally only for ‘geographical departures and unauthorized on-deck stowage’, not for a botched delivery.