Parrot v. Wells, Fargo & Co.

82 U.S. 524 · Supreme Court of the United States · 1873

Facts

Express carriers received a case of nitro-glycerine, unaware of its dangerous contents and having no reason to suspect it. An explosion occurred while handling the case, damaging the plaintiff's buildings. The court found no negligence by the defendants in receiving or handling the package.

Issue

Can a plaintiff recover for damages caused by an explosion of dangerous goods handled by a carrier, when the carrier was innocently ignorant of the contents and not negligent?

Holding

No, the plaintiff cannot recover. The court held that the defendants were not liable for damages resulting from an unavoidable accident without proof of negligence.

Rule

A carrier is not liable for damages caused by dangerous goods if they were innocently ignorant of the contents, had no means of knowledge, and no reasonable ground for suspicion. The burden of proving negligence rests on the plaintiff, and injuries from unavoidable accidents in lawful business do not incur liability without such proof.

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Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.