Puerto Rico Maritime Shipping Authority v. Federal Maritime Commission

                United States Court of Appeals
                    For the First Circuit

                                         

No. 95-1643

           PUERTO RICO MARITIME SHIPPING AUTHORITY,

                         Petitioner,

                              v.

                 FEDERAL MARITIME COMMISSION
                             and
                   UNITED STATES OF AMERICA

                         Respondents.

                                         

                        STANLEY HECHT

                         Intervenor.

                                         

              PETITION FOR REVIEW OF AN ORDER OF
               THE FEDERAL MARITIME COMMISSION

                                         

                            Before

                     Lynch, Circuit Judge,
                                                     
               Campbell, Senior Circuit Judge,
                                                         
                  and Watson,* Senior Judge.
                                                       

                                         

   Amy  Loeserman Klein, with  whom Jenkens &  Gilchrist was on
                                                                    
brief, for petitioner Puerto Rico Maritime Shipping Authority.
   Carol  J. Neustadt,  Attorney, Federal  Maritime Commission,
                                 
with whom  Robert D. Bourgoin,  General Counsel, and  C. Douglass
                                                                           
Miller,  Attorney,  Federal  Maritime  Commission,  and  Anne  K.
                                                                           
Bingaman,  Assistant Attorney  General,  John J.  Powers III  and
                                                                      
                  
                              

   *Of  the  U.S.  Court  of International  Trade,  sitting  by
designation. 


Robert J. Wiggers, Attorneys, U.S. Department of Justice, were on
                           
brief,  for respondents  Federal  Maritime Commission  and United
States of America.
   Rick A. Rude for intervenor Stanley Hecht.
                           
   Nathan  J. Bayer, with whom  Torbjorn B. Sjogren  and Sher &
                                                                           
Blackwell  were on brief, for amici curiae United States Atlantic
                                                    
and   Gulf/Southeastern   Caribbean  Conference,   United  States
Atlantic and Gulf Hispaniola Steamship Freight Association, Latin
American  Shipping  Service   Association,  Venezuelan   American
Maritime Association and the Credit Agreement.

                                         

                       February 6, 1996
                                         


          LYNCH,  Circuit  Judge.   May the  Federal Maritime
                      LYNCH,  Circuit  Judge.
                                            

Commission,  in  exercising   its  administrative   lawmaking

function, excuse a party from  paying sums awarded against it

by  a final  judgment entered  by a  U.S. District  Court and

affirmed  on appeal?   We  preserve harmony  between the  two

systems  of law  and  respect for  judgments  entered by  the

courts by concluding,  on the  facts of this  case, that  the

party was  not free  before the  agency to  seek to undo  the

court  judgment.      Accordingly,  we   reverse  the   FMC's

determination that  Save-On Shipping  (SOS) need not  pay the

attorneys'  fees and  costs awarded  to Puerto  Rico Maritime

Shipping  Authority  (PRMSA)  by the  United  States District

Court  for the Southern District of Florida and by the United

States Court of  Appeals for  the Eleventh Circuit.   To  the

extent  that the  FMC's  order is  prospective  and does  not

involve sums awarded by the judgment entered, we affirm.

          PRMSA  carried four  shipments  of frozen  food and

other  items to  San Juan,  Puerto  Rico for  SOS.   When SOS

refused  to pay about $11,000 of PRMSA's bill, PRMSA began an

action  against SOS in  the federal court  in Florida seeking

the unpaid  freight charges,  interest, collection  costs and

attorneys' fees  pursuant to  the  terms of  PRMSA's bill  of

lading  to SOS.1   Jurisdiction  was under  the maritime  and

                    
                                

1.  PRMSA's lawsuit in federal district court was filed by an
agent of PRMSA, Puerto  Rico Marine Management, Inc. (PRMMI),
and the judgment  in the federal court action ran in favor of

                             -3-
                                          3


admiralty  jurisdiction of  the federal  courts, 28  U.S.C.  

1333.  The bill of lading, which employed language found in a

bill of lading tariff filed with the FMC, provided that: 

          [t]he shipper, consignee, holder hereof, and owners
          of the goods shall  be jointly and severally liable
          to  Carrier  for  the   payment  of  all   freight,
          demurrage,  General  Average  and   other  charges,
          including, but not limited to court costs, expenses
          and   reasonable   attorney's   fees  incurred   in
          collecting sums due Carrier.

SOS moved for summary judgment;  PRMSA filed a cross  motion.

SOS lost on both motions.  The court awarded PRMSA the unpaid

freight, attorneys'  fees and  costs, enforcing the  terms of

the bill of lading.

          SOS moved  for reconsideration and then  for a stay

of  the  district  court   proceeding  while  SOS  pursued  a

complaint (FMC Docket  No. 92-12) it had  filed (after losing

the  summary   judgment  motions)  before  the   FMC.    That

administrative   complaint   challenged,   inter  alia,   the
                                                                  

attorneys' fees provision of the  tariff upon which the  bill

of  lading was  based,  but did  not  directly challenge  the

attorneys' fees awarded on the four shipments at issue in the

federal court action.   It asserted that the  attorneys' fees

tariff provision was unreasonable under sections 17 and 18(a)

of the Shipping Act of 1916, 46 U.S.C. app.    816 and 817(a)

(the 1916  Act), and section  2 of the  Intercoastal Shipping

                    
                                

PRMMI.   Because the distinction  between PRMSA and  PRMMI is
unimportant to the disposition of this petition, this opinion
refers only to PRMSA.

                             -4-
                                          4


Act  of  1933, 46  U.S.C.  app.    844  (the 1933  Act).   It

involved  seven  shipments  on  which PRMSA  had  not  sought

freight  collection  in  the   court  action.    Because  the

shipments had occurred two  years prior to the filing  of the

administrative complaint, SOS sought only  prospective relief

in the form  of cease and desist orders.   SOS's motion for a

stay of  the district  court proceedings  was the first  time

that SOS argued before the district court that the attorneys'

fees  provision might  be  illegal or  unreasonable and  thus

unenforceable because it  was unilateral.   The motion for  a

stay   did  not   argue  that   the  district   court  lacked

jurisdiction  over   the  attorneys'  fees  issue.    Rather,

recognizing   that  primary   jurisdiction  is   a  rule   of

"deference" and  not of jurisdiction, it  argued that primary

jurisdiction  was in the FMC.  The district court denied both

of SOS's motions.

          SOS  appealed the  judgment  to the  United  States

Court of Appeals for  the Eleventh Circuit and moved  to stay

the appellate  proceedings or,  in the alternative,  to refer

the   case  to  the   FMC  under  the   doctrine  of  primary

jurisdiction.   The  Eleventh Circuit  denied the  motion for

stay.  It later affirmed the district court, without opinion,

and  denied the  motion  for referral  as  moot.   PRMSA  was

eventually awarded attorneys' fees and costs of approximately

                             -5-
                                          5


$100,000.  The  parties do not  identify any further  appeals

taken by SOS in the federal court action pertinent here.

          Having lost  in federal  court, SOS filed  a second

complaint  before the  FMC  (FMC Docket  No. 93-21)  directly

challenging the attorneys' fees awarded on the four shipments

that  were   at  issue  in   the  Eleventh  Circuit.     This

administrative  complaint also  alleged that  the tariff  and

bill of lading language  concerning attorneys' fees and costs

was  unlawful  and  unreasonable.    It   sought  reparations

pursuant to section 22(a)  of the 1916 Act, 46  U.S.C. app.  

821(a), in the amount of attorneys' fees that were granted by

the  federal  court.   The  FMC  eventually consolidated  FMC

Docket No. 92-12 and  FMC Docket No. 93-21 on  the attorneys'

fees issue.

          The  FMC agreed  with  SOS on  the attorneys'  fees

issue.  The FMC held that  because the bill of lading  tariff

provision was  unilateral (allowing the carrier,  but not the

shipper,  to recover fees and costs), it was in conflict with

an FMC decision,  West Gulf Maritime  Ass'n v. Galveston,  22
                                                                    

F.M.C.  101   (1979),  and  the  provision   was  unjust  and

unreasonable.  It granted SOS's relief in both FMC Docket No.

92-12 and  FMC Docket  No. 93-21.   In  so doing,  it decided

three issues  of relevance here.   It first  rejected PRMSA's

argument that  claim preclusion barred  the reparations claim

in FMC Docket No. 93-21 as  to the four shipments involved in

                             -6-
                                          6


the  court action.    It next  ordered PRMSA  to pay  back as

reparations  in  FMC  Docket   No.  93-21  any  amount  PRMSA

collected in  attorneys' fees  pursuant to the  federal court

judgment.  It also granted SOS's motion for summary  judgment

in  FMC Docket  No. 92-12  seeking a  cease and  desist order

preventing PRMSA  from publication and  attempted enforcement

of the provisions of FMC-F-No. 10 (the bill of lading tariff)

and its  bill  of lading  allowing for  costs, expenses,  and

attorneys' fees.

          PRMSA has  petitioned here for review  of the FMC's

order.    The FMC  and  the  United  States are  respondents;

Stanley  Hecht,   president  of  SOS,  has   appeared  as  an

intervenor.2    In  its  petition, PRMSA  presses  the  claim

preclusion argument it made  before the FMC.  It  also claims

that  the FMC's decision on the merits of the attorneys' fees

issue was error. 

          Because the question of claim preclusion is  purely

a  matter of law within  the expertise of  the federal courts

and  is not a question within the particular expertise of the

FMC, our  review  of that  issue  is plenary.   Cf.  Dion  v.
                                                                     

Secretary  of Health and Human Servs., 823 F.2d 669, 673 (1st
                                                 

Cir. 1987).   We  also  note the  doctrine that  "[j]udgments

                    
                                

2.  PRMSA's suit in the district court was filed against both
SOS and Stanley  Hecht.  Midway  through the litigation,  SOS
represented  that  it  had  gone  out  of  business, and  the
litigation  was carried on only in the name of Stanley Hecht.
In this opinion, "SOS" designates both parties.

                             -7-
                                          7


within the powers vested  in courts by the  Judiciary Article

of the  Constitution may not lawfully  be revised, overturned

or  refused  faith  and   credit  by  another  Department  of

Government."  Chicago & Southern Air Lines, Inc. v.  Waterman
                                                                         

S.S. Corp., 333  U.S. 103,  113 (1948).   Because we  believe
                      

that  FMC Docket  No.  93-21 was  barred under  principles of

claim preclusion, we  reverse the FMC's order with respect to

FMC Docket No. 93-21 including its order granting reparations

of the  amount of attorneys' fees collected by PRMSA pursuant

to the federal  court action.   We do  not, however,  believe

that FMC  Docket No. 92-12  was barred  and, in light  of our

deferential review of the FMC's  construction of a statute it

administers, see  Chevron U.S.A.,  Inc. v.  Natural Resources
                                                                         

Defense Council,  467 U.S.  837 (1984),  we affirm  the FMC's
                           

order in that case.

          1. FMC  Docket  No. 93-21:  The Reparations  Claim.
                                                                        

Since  the identity  of the  parties and  the existence  of a

final  judgment on the merits are not in dispute, the parties

have  focussed  on  whether  there  was  sufficient  identity

between  the  causes  of  action actually  litigated  in  the

federal court action and the claim for reparations before the

FMC.  We do not enter the fray, as do the parties,  for under

the principle of claim preclusion,  "'a final judgment on the

merits of  an action precludes  the parties or  their privies

from relitigating issues  that were or could have been raised
                                                                         

                             -8-
                                          8


in  that action.'"  Manego v.  Orleans Bd. of Trade, 773 F.2d
                                                               

1, 5  (1st Cir. 1985) (quoting Allen v. McCurry, 449 U.S. 90,
                                                           

94 (1980)  (emphasis supplied)), cert. denied,  475 U.S. 1084
                                                         

(1986);  accord  Kelly v.  Merrill  Lynch,  Pierce, Fenner  &
                                                                         

Smith, Inc., 985  F.2d 1067, 1070 (11th  Cir.), cert. denied,
                                                                        

114 S. Ct. 600 (1993).

          The   claims   of   unreasonableness,  and   hence,

illegality, of the attorneys' fees  provision in the bill  of

lading could  have been raised  as an affirmative  defense in

the  action  over  which   the  district  court  plainly  had

jurisdiction.       Although    SOS   could    have    raised

unreasonableness as  an affirmative defense and requested the

district court to stay  the action and refer the  question to

the  FMC as a matter of primary jurisdiction, see Holt Marine
                                                                         

Terminal,  Inc. v. United States Lines, 472 F. Supp. 487, 489
                                                  

(S.D.N.Y. 1978);  cf. P.R. Maritime Shipping  Auth. v. Valley
                                                                         

Freight Sys., 856 F.2d  546, 549 (3d Cir. 1988)  (referral to
                        

Interstate  Commerce Commission),  the decision to  refer was

within the discretion of  the federal court.   Valley Freight
                                                                         

Sys.,  856 F.2d at 549.  The doctrine of primary jurisdiction
                

does  not implicate  the subject  matter jurisdiction  of the

federal court.  Id.
                               

          Normally,  this would  be  the end  of the  matter.

Under the transactional approach of the Restatement  (Second)

of Judgments    24  (1980) applicable  here, see Manego,  773
                                                                   

                             -9-
                                          9


F.2d at  5; see also Wallis  v. Justice Oaks II,  Ltd. (In re
                                                                         

Justice Oaks  II,  Ltd.), 898  F.2d  1544, 1551  (11th  Cir.)
                                    

(applying   Restatement's   transactional  approach),   cert.
                                                                         

denied,  498 U.S.  959 (1990), defendants  can no  more split
                  

defenses arising  out of  the same transaction  or occurrence

than plaintiffs can split claims.  Even if  SOS's reparations

claim  before  the FMC  is  characterized  as a  counterclaim

rather  than  an  affirmative  defense,  it  would not  be  a

separate cause  of action.   The reparations claim,  which is

based on the very same four shipments at issue in the federal

court  collection  action,  clearly  arose out  of  the  same

transaction  or occurrence  and  virtually all  of the  facts

necessary  to the  reparations  claim would  have formed  the

basis of a  defense to the collection action.   Cf. Pirela v.
                                                                      

Village  of North Aurora, 935 F.2d 909, 912 (7th Cir.), cert.
                                                                         

denied, 502 U.S. 983 (1991).
                  

          Indeed,   the   required   joinder  of   compulsory

counterclaims,  see Fed.  R.  Civ. P.  13(a) and  Restatement
                               

(Second) of Judgments    22, is  designed to prevent  parties

from hiding  behind formal distinctions between  defenses and

counterclaims.  Under  usual circumstances, SOS's reparations

claim would be a compulsory counterclaim and SOS's failure to

assert  it in the federal  court action would  have barred it

from bringing it in a subsequent action.  See id.
                                                             

                             -10-
                                          10


          The  FMC urges  that those  usual rules  should not

apply,  relying  on the  opinion  in  Government  of Guam  v.
                                                                     

American President Lines, 28 F.3d 142 (D.C. Cir. 1994).  That
                                    

case held that there is no express or implied cause of action

in federal  district courts  over reparations claims  brought

under either the  1916 Act or  the 1933  Act.3  The  argument

goes that SOS  cannot be barred  from pursuing a  reparations

action  that  could  not  have been  brought  in  the federal

district  court.  That argument begs the question.  The issue

here  is  whether  principles  of claim  preclusion  bar  the

assertion of  a claim before  an agency  which is based  on a

legal theory that could have been raised by way of defense to

                    
                                

3.  In  Government of  Guam the  shippers first  initiated an
                                       
action before  the FMC  against carriers for  reparations for
rates  alleged to be unlawful  under the 1916  and 1933 Acts.
The  shippers  later filed  a  virtually  identical claim  in
federal court  which the court  dismissed.  The  D.C. Circuit
affirmed the dismissal.  The  shippers conceded that the  FMC
had the task of resolving the  merits of the dispute, 28 F.3d
at  144, and there was  no private cause  of action expressly
provided in the 1916 and 1933 Acts for a shipper to challenge
a carrier's rates in  federal court.  The shippers  sought to
continue  the  court action  in  order  to preserve  ultimate
claims of a  class, claims which the FMC could  not hear, and
argued  there was  an  implied cause  of  action.   The  D.C.
Circuit declined to imply a cause of action.
          In  contrast,  here, the  carrier  had  a cause  of
action  that was properly before the federal court.  There is
little reason  to think the Government of Guam court intended
                                                          
to resolve  a dispute of  the sort  faced on the  facts here.
Indeed,  in a separate part of the opinion, the Government of
                                                                         
Guam  court declined  to  give the  shippers relief  from the
                
consequences of  their failure  to have raised  certain legal
theories in the district court.  Id. at 149-50.  
                                                

                             -11-
                                          11


the  district court claim and  which, if it  had been raised,

could have provided the same relief.

          A defendant  is barred from  relitigating a defense

which was available in a prior action by making it  the basis

of  a claim that would "nullify the initial judgment or would

impair   rights   established   in   the   initial   action."

Restatement (Second) of Judgments    22(2)(b).  A defendant's

failure to raise such a defense precludes  the defendant from

seeking restitution  of the amount that may have been awarded

to the plaintiff in the first action.  Id. cmt. b & f, illus.
                                                      

2, 3,  9.  The reparations  action SOS seeks in  this case is

precisely the type of  restitutionary remedy that, under this

rule,  is barred.    Were SOS  to  be allowed  a  reparations

remedy, the  district court's award of  attorneys' fees would

be  rendered  totally  meaningless   and  there  would  be  a

concomitant waste of  judicial resources.  We hold that SOS's

claim for reparations before the FMC is barred.

          The  policies of  economy,  efficiency, repose  and

fairness underlying  the claim  preclusion doctrine are  best

served  by holding SOS to the consequences of its actions and

inactions.  Under the facts of  this case, SOS had a full and

fair opportunity to litigate the attorneys' fees issue before

the  district court.4  Although  it had an  opportunity to do

                    
                                

4.  A  defendant  must,  of  course,  have  a  full and  fair
opportunity to raise the  claim in the first action.   In the
analogous  situation  of  plaintiffs'  claim  splitting,  for

                             -12-
                                          12


so,  SOS  neither raised  the  reparations  claim before  the

federal  court nor argued that there was no jurisdiction over

the  attorneys' fees  issue.   SOS,  as  a result,  gains  no

benefit  from  any   jurisdictional  competency  or   "formal

barrier" exception to the doctrine  of claim preclusion.  Cf.
                                                                         

Restatement (Second)  of Judgments   26(1)(c).   Further, the

Government of Guam  outcome was not supported by precedent in
                              

the Eleventh  Circuit  nor is  it  binding on  that  circuit.

Indeed, the FMC  itself has  in the past  taken the  position

that  federal  courts   have  concurrent  jurisdiction   over

reparations claims brought  under section 22 of the  1916 Act

and  that  a  reparations  counterclaim could  be  raised  in

federal  district court.    See Interconex,  Inc. v.  Federal
                                                                         

Maritime Comm'n, 572 F.2d 27, 30 (2d Cir. 1978).
                           

          There is virtually  no practical difference between

the relief SOS  could have received before the district court

and what it sought before  the FMC.  The legal theory  -- the

unreasonableness of the  unilateral attorneys' fees provision

-- was available to  SOS in the district  court action.   The

extent of the  relief sought  -- relief from  payment of  the

attorneys' fees -- was available in the district court.

                    
                                

example, the Restatement recognizes that the first court must
have   been  competent   to  adjudicate   the  claim.     See
                                                                         
Restatement (Second) of Judgments   26(1)(c);  see also id.  
                                                                       
22(2)  (claim preclusion  over  counterclaims  is limited  to
claims  that the  defendant  "may [have]  interpose[d]" as  a
counterclaim in the first action).   

                             -13-
                                          13


          The  purely  formal distinctions  on which  FMC and

intervenor uneasily rest have met with considerable hostility

when used as attempts to avoid claim preclusion. For example,

parties who  have failed to raise fraud  and forgery defenses

in state  court actions have  been barred from  bringing RICO

claims in  federal court based  on allegations  of fraud  and

forgery even where  jurisdiction over the RICO claim may have

been  exclusively federal.   See, e.g., Henry  v. Farmer City
                                                                         

State Bank,  808 F.2d  1228, 1236-37  (7th  Cir. 1986);  cf.,
                                                                        

also, Pirela, 935 F.2d  at 912.  The underlying  rationale is
                        

that  claim preclusion applies if the formal barriers did not

prevent the party  from a  full and fair  opportunity in  the

first action to  litigate the substance  of the legal  theory

advanced and remedy sought in the second action.

          Finally, the results  reached here with respect  to

the reparations  action are  not outweighed by  concerns over

the  1916 and 1933 Acts' statutory scheme.  Cf., e.g., United
                                                                         

States v. American Heart  Research Found., Inc., 996 F.2d  7,
                                                           

11 (1st  Cir. 1993) (claim-splitting limitation relaxed where

applying  it  would  frustrate  a statutory  objective).    A

different  factual setting  might more  strongly involve  the

policies behind the 1916 and 1933 Acts, but this is basically

an  action between two private parties over who will bear the

costs and  fees of the collection  action here.   In order to

collect $11,000 in freight charges, an amount SOS says it has

                             -14-
                                          14


now paid and does not dispute, PRMSA was forced to spend over
                     

$100,000  in  attorneys'  fees.     That  Congress  may  have

preferred that the FMC decide questions of the reasonableness

of  attorneys' fees  provisions in  carrier tariffs  does not

justify  upsetting   the  strong  policy  of  honoring  final

judgments  entered   by  federal   courts.    Cf.   Plaut  v.
                                                                     

Spendthrift Farm,  Inc., 115 S. Ct.  1447 (1995) (retroactive
                                   

legislation which reverses a judgment within the power vested

by  the   courts  is  unconstitutional  as   a  violation  of

separation  of  powers).   Nor does  it excuse  compliance by

litigating  parties  with  general  rules  of  federal  claim

preclusion.

          SOS  had a  range  of actions  available, which  it

chose  not  to  follow,  that  would  have  accommodated  the

interests of both  the judicial  and administrative  systems.

Before SOS was  sued, it could have paid PRMSA's bill and the

fees  and  then  brought  an   action  before  the  FMC   for

reparations.    Alternatively,  once  sued,  SOS  could  have

asserted an  affirmative defense of illegality and/or brought

a  reparations counterclaim  in district  court and  sought a

ruling on  the question of  whether there was  subject matter

jurisdiction  over  the reparations  counterclaim.   It could

also have  brought a timely  action in the  FMC and  it could

have  asked in  a timely fashion  for a stay  of the district

court action or  a primary jurisdiction  referral.  It  could

                             -15-
                                          15


also  have  asked the  district  court to  make  its decision

without  prejudice to pursuing  the reparations  claim before

the FMC.  See Restatement (Second) of Judgments   26(1)(b).
                         

          On  these particular facts and equities,5 the FMC's

decision that SOS was free to avoid claim preclusion and thus

the  federal court judgment against it  on the four shipments

for costs and attorneys' fees is, we believe, in error and is

reversed.

                    
                                

5.  The  result  reached  here  coincides  with  the  results
reached  in  Delta  Traffic Serv.,  Inc.  v.  Georgia-Pacific
                                                                         
Corp., 936  F.2d  64  (2d Cir.  1991),  which  addressed  the
                 
jurisdictional  relationship between  the federal  courts and
the   Interstate   Commerce   Commission   (ICC)   over  rate
reasonableness  issues.   In  that case,  the Second  Circuit
denied requests to remand  the case to the district  court to
assert rate  reasonableness defenses that were  not raised in
the  district court,  but stated  that Georgia-Pacific  could
nevertheless continue to pursue  a reparation action based on
rate unreasonableness  before the ICC.   See id.  at 66.   In
                                                            
Georgia-Pacific, however, Georgia-Pacific requested a stay of
                           
the  district  court  action  and   a  referral  to  the  ICC
"[c]oincident with the service of its answer"  in the federal
action.   Id. at 65.  Moreover, the rate reasonableness issue
                         
was  pending before  the ICC  before judgment entered  in the
federal  court action.  Aware  of the ICC  action, the Second
Circuit carefully  limited the  scope of its  decision, which
may  have restricted  any claim  preclusive effects  it might
otherwise have had.  Id.  at 66; see 18 Charles A.  Wright et
                                                
al., Federal Practice  and Procedure   4413 (1981).  Georgia-
                                                                         
Pacific does not stand  for the proposition that a  party may
                   
collaterally  attack  a  federal court's  final  judgment  by
raising  before an  agency a  claim based  on a  defense that
could  have been, but was  not, raised in  the federal court.
Indeed,  in a  similar case  the Second  Circuit had  earlier
refused to undermine a  federal district court judgment based
on a rate unreasonableness defense raised for the  first time
on  appeal.  See Delta Traffic Service, Inc. v. Appco Paper &
                                                                         
Plastics Corp., 931 F.2d 5, 7 (2d Cir. 1991).
                          

                             -16-
                                          16


          2. FMC  Docket No. 92-12: Cease  and Desist Orders.
                                                                        

The issues raised by the appeal from the other administrative

complaint  are different, as is the outcome.  As PRMSA states

in its brief, the seven shipments at issue in  FMC Docket No.

92-12  were never part of the federal court action brought by

PRMSA.  Even if  these seven shipments arose out  of the same

transaction  or occurrence  (which is  unclear on  the record

before  us), as they  must for  PRMSA successfully  to assert

claim preclusion,  the bar would  work against PRMSA.   PRMSA

would  then have  split its  claim and  would be  barred from

suing  on the seven shipments.  A defendant has no obligation

to raise  affirmative defenses to  claims that have  not been

brought against it.  Cf.  Restatement (Second) of Judgments  
                                    

22 cmt. b. 

          The pertinent statutes are  silent on the merits of

whether the  attorneys' fee  provision in PRMSA's  tariff and

bill of  lading was  unreasonable because it  was unilateral.

We  defer to  the expertise  of the  FMC on  the issue.   See
                                                                         

Chevron,  467 U.S. at 842-43.   Section 18(a) of the 1916 Act
                   

provides  that carriers  will enforce  "just  and reasonable"

tariffs  and practices  relating  thereto. 46  U.S.C. app.   

817(a).   The FMC, which administers the 1916 Act, is charged

with deciding whether  a carrier's tariff and  bill of lading

is "just  and reasonable."   In light of the  fact that these

provisions are  ubiquitous  and shippers  have no  meaningful

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                                          17


ability  to  avoid  the  provision,  the  FMC held  that  the

attorneys'  fees  and  costs   provision  was  not  just  and

reasonable under  a prior  analogous FMC decision,  West Gulf
                                                                         

Maritime Ass'n  v. Galveston,  22 F.M.C. 101  (1979) (holding
                                        

unreasonable under section  17 of the 1916  Act an attorneys'

fees provision  that allowed a  terminal operator, but  not a

user,  to collect attorneys' fees).   We recognize that, West
                                                                         

Gulf   notwithstanding,  two   of  the   FMC's  commissioners
                

dissented  from  the  decision  at issue  here  and  that the

question of unreasonableness of the attorneys' fees provision

is by no  means free from doubt.   But the FMC's construction

of the statute appears  to be permissible.  See  Chevron, 467
                                                                    

U.S.  at 842-43.  We therefore affirm the FMC's order insofar

as it relates to FMC Docket No. 92-12.

                         Conclusion 

          The  judgment  of  the  FMC is  reversed  in  part,
                                                              

affirmed in part, and remanded  with directions that the  FMC
                                          

dismiss  FMC  Docket  No.  93-21  and  modify  its  order  in

accordance with  this opinion.   Parties  to bear  their  own

costs on appeal.  It is so ordered.
                                              

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