AIG Europe (Netherlands), N v. v. UPS Supply Chain Solutions, Inc.
Plaintiff AIG Europe (Netherlands), N.V. ("AIG") initiated a subrogation action against Defendant UPS Supply Chain Solutions, Inc. ("UPS") following damage to an x-ray machine during shipment. AIG, acting as the insurer for Philips Medical Systems Nederlands, B.V., asserted claims for breach of contract, bailment obligations, and tort. UPS sought summary judgment to limit its liability to $9,479.61, while AIG cross-moved for summary judgment, arguing against the enforceability of any liability limitation and its invalidity under the Carmack Amendment. The Court denied both motions for summary judgment on the contractual liability issues, citing genuine disputes of material fact regarding the existence and terms of a binding agreement between the parties. Furthermore, the applicability of the Carmack Amendment and the material deviation doctrine could not be determined as a matter of law. However, UPS's motion for summary judgment on AIG's tort claim was granted as it was unopposed.