Healy v. N.Y. Central & Hudson River R.R. Co.
Supreme Court of New York, Appellate Division, Third Department
138 N.Y.S. 287 (1912)
Healy (plaintiff) checked a handbag at a railroad parcel room operated by New York Central & Hudson River Railroad Company (the Railroad) (defendant) and received a claim coupon whose fine print limited the Railroad's liability to $10 for any loss or damage. Healy pocketed the coupon without reading it and had no actual knowledge of the limitation. When the Railroad misplaced his handbag, Healy sued to recover its full value, $70.10. The trial court ruled for Healy, and the Railroad appealed, arguing the printed limitation controlled.
Whether a printed liability-limiting provision on a baggage claim coupon binds a customer who never actually knew about the limitation because it was printed in small type he never read.