King Jewelry, Inc. v. Federal Express Corporation

King Jewelry, Inc. (“King Jewelry”) appeals the grant of partial summary judgment limiting Federal Express Corporation’s (“Federal Express”) liability for damage to a shipment of candelabra. We affirm because we find that: (1) the district court appropriately found that the candelabra were “items of extraordinary value” as defined in the contract; (2) federal common law governs the limited liability provision; and (3) Federal Express complied with the released valuation doctrine and successfully limited its liability to $500.00 per crate. However, because Federal Express concedes that it should return the excess valuation charge King Jewelry paid, we modify the damages accordingly.

I. FACTS AND PROCEDURAL HISTORY

This case arises from damage caused to a shipment of candelabra when Federal Express transported them from Florida to California. King Jewelry contracted with a professional packager, Raymie’s, in Florida to package and ship the candelabra to California. The candelabra were valued at $37,000.00.

After discussing the shipment with several other companies who refused to ship such a high value item, Raymie’s contacted Federal Express. Raymie’s asserts that the Federal…