## Facts

- Lloyd M. Crenshaw held an insurance policy issued by Bankers Life & Casualty Co. providing $20,000 for loss of a limb.
- After an accident involving a car alternator, Crenshaw suffered complications culminating in a below-the-knee amputation.
- Bankers Life denied coverage, asserting the amputation resulted from a preexisting condition rather than the accident.
- Crenshaw sued in Mississippi state court for policy benefits and punitive damages based on bad-faith refusal to pay.
- A jury awarded $20,000 in contractual damages and $1.6 million in punitive damages.
- The Mississippi Supreme Court affirmed and imposed a statutory 15% penalty for an unsuccessful appeal from a money judgment whose value could be readily determined.
- In post-judgment filings, Bankers Life asserted constitutional objections to the punitive damages and separately claimed the 15% penalty violated equal protection; the state court denied relief without opinion.

## Issues

1. Whether federal constitutional challenges to the punitive damages award (Due Process Clause, Contract Clause, and Excessive Fines Clause) were reviewable when not specifically raised and resolved in the Mississippi courts.
2. Whether Mississippi’s statute imposing a 15% penalty on unsuccessful appeals from certain money judgments violates the Equal Protection Clause of the Fourteenth Amendment.

## Decision

- The Court affirmed the Mississippi Supreme Court.
- The Court declined to decide the federal constitutional challenges to the punitive damages award because the specific federal theories were not properly presented to, and passed upon by, the state courts.
- The Court held that the 15% unsuccessful-appeal penalty statute does not violate equal protection because it is rationally related to legitimate state interests.

## Legal Principles

- The Supreme Court generally will not decide federal constitutional questions that were not clearly raised and passed upon in state court; generalized references to “constitutional principles” or “excessiveness” may be insufficient to preserve specific federal claims.
- A state statute that does not involve a suspect classification or fundamental right is evaluated under rational-basis review for equal protection purposes.
- Under rational-basis review, a classification is valid if it is rationally related to legitimate state interests, including deterring frivolous or dilatory appeals, compensating appellees for delay and appellate costs, and conserving judicial resources.
- An appeal-penalty scheme applying broadly to money-judgment appellants may satisfy equal protection even if it is not perfectly tailored.

## Conclusion

The Court upheld Mississippi’s across-the-board 15% penalty for unsuccessful appeals from certain readily calculable money judgments under rational-basis equal protection review and refused to reach Bankers Life’s constitutional objections to the punitive damages award because those federal issues were not adequately preserved in the state proceedings.


Bankers Life & Casualty Co. v. Crenshaw, 486 U.S. 71 (1988)