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In the case of Voeller et al. v. Neilston Warehouse Co. et al., 1940, the United States Supreme Court ruled on a dispute between grain elevator operators and their customers over who should bear the cost of federal taxes levied on warehouse receipts under the Agricultural Adjustment Act (AAA). The AAA was enacted to stabilize agricultural prices during the Great Depression by imposing taxes on certain commodities, including grain stored in warehouses. The plaintiffs argued that they were not liable for these taxes because they had already paid storage fees to warehouse operators who issued them receipts for their deposited grain. However, both lower courts held that as per contractual agreement between parties involved, it was understood that any government tax would be borne by depositors (customers), not warehousemen. The Supreme Court affirmed this decision unanimously stating that while there is no explicit provision in contracts about bearing such costs; however, based upon common business practices and understanding at time when contracts were made - it can be inferred that such charges are typically passed onto consumers or users of service rather than providers themselves.
The dissenting opinion in the case of Voeller et al. v. Neilston Warehouse Co. et al., argued that the majority's decision to uphold a lower court ruling, which held warehousemen liable for damages caused by rats to goods stored in their facility, was incorrect and inconsistent with established principles of law regarding bailment contracts. The dissent contended that the warehouse company had taken reasonable precautions against rat infestation and should not be held responsible for an act of nature beyond its control or prediction. It further asserted that such liability would place an unreasonable burden on businesses providing storage services, potentially leading them to refuse storing certain types of goods out of fear they could be held accountable for any damage regardless their efforts to prevent it.