James Clark McReynolds,
St. Johns Shipping Corporation v…
“ When issued under such circumstances the bill amounted to a declaration that the option had been exercised and the goods would go under deck.We are not dealing with a case arising under a general port custom permitting above deck stowage notwithstanding a clean bill, with notice of which all shippers are charged. When there is no such custom and no express contract in a form available as evidence, a clean bill of lading imports under deck stowage. ”
