Mauricio Importadora y Exportadora v. Jet Speed Logistics (USA), LLC
A Chilean importer sued a non-vessel operating common carrier in state court for negligence, conversion and replevin after more than 1,200 of 3,500 laptops went missing in transit from Miami to Chile. The Third DCA affirmed a directed verdict for the carrier, holding that because the bill of lading expressly extended the Carriage of Goods by Sea Act (COGSA) to pre-loading and post-discharge periods, COGSA completely preempted the state law claims and its one-year limitations period barred the suit.
Key facts
- Chilean importer Mauricio Importadora y Exportadora sued non-vessel operating common carrier Jet Speed Logistics for negligence, conversion, and replevin in Florida state court after more than 1,200 of 3,500 laptops disappeared during transit from Miami to Chile.
- The bill of lading expressly extended COGSA coverage to pre-loading and post-discharge periods; the carrier moved for directed verdict based on COGSA preemption and its one-year statute of limitations.
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Why it matters
This is a rare Florida state-court decision applying COGSA's complete preemption and one-year limitations bar to common-law claims (including conversion) arising from cargo loss during the inland, pre-loading leg of an… — full analysis with a trial
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