Steel Coils, Inc. v. M/V Lake Marion
United States Court of Appeals for the Fifth Circuit
331 F.3d 422 (2003)
Steel Coils, Inc. (plaintiff) shipped steel coils from Russia to the United States on the M/V Lake Marion, owned and operated by the defendants, who never tested whether the ship's hatches were watertight. Bills of lading and a cargo survey confirmed the coils were in good condition at loading; tests at the destination port confirmed sea-water damage at unloading. Steel sued under the Carriage of Goods by Sea Act (COGSA), and the district court entered judgment for Steel. The defendants appealed, arguing the district court misapplied COGSA's burden of proof and defenses.
Whether, under COGSA, a shipping carrier can shift the burden of proof back to the cargo owner to show the carrier's negligence caused the damage, once the cargo owner has established a prima facie case of damage during transit.