## Facts

- Arkansas set maximum intrastate passenger fares and created a civil action allowing an overcharged passenger to recover a statutory penalty of $50–$300 per offense, plus costs and a reasonable attorney’s fee.
- In June 1915, an Arkansas railroad overcharged two sisters 66 cents each on intrastate travel.
- Each sister sued and recovered the 66-cent overcharge, a $75 statutory penalty, costs, and a $25 attorney’s fee; the actions were consolidated.
- The railroad challenged the penalty provision as violating the Fourteenth Amendment Due Process Clause.
- Arkansas courts upheld the statute and judgments; the railroad sought review in the U.S. Supreme Court.

## Issues

1. Whether the penalty scheme was so severe that it effectively prevented the railroad from obtaining judicial review of the legality of the prescribed passenger rate, in violation of due process.
2. Whether a $50–$300 per-offense penalty (as applied via $75 penalties for 66-cent overcharges) was arbitrary and unreasonable under due process because it exceeded actual damages.

## Decision

- The Supreme Court affirmed the Arkansas judgment.
- The Court held that due process was not violated on an access-to-courts theory because the railroad had a realistic avenue to test the rate’s validity in a proceeding where the penalty could be suspended pending review.
- The Court held that the penalties were not unconstitutional merely because they exceeded the particular overcharges; they were not so severe and oppressive as to be wholly disproportionate to the offense and obviously unreasonable.

## Legal Principles

- A state may enforce valid rate regulation with penalties; due process is implicated only where severe penalties attach without an adequate opportunity for the regulated party to obtain safe pre-enforcement judicial testing of the rate.
- Statutory penalties are judged against the offense and the public objective of securing uniform compliance, not solely against the plaintiff’s private monetary loss in a given instance.
- Legislatures have broad discretion to set civil penalties and fee-shifting mechanisms to secure obedience to valid laws; due process is violated only if the penalty is wholly disproportionate to the offense and obviously unreasonable.
- Allowing private parties to sue for fixed statutory penalties and attorney’s fees, even beyond actual damages, can be consistent with due process when used to enforce a lawful regulatory regime.

## Conclusion

The Court upheld Arkansas’s civil-penalty and fee-shifting scheme for intrastate fare overcharges, ruling that the railroad had adequate means to seek judicial review and that the penalties, though far exceeding the 66-cent overcharges, were not so disproportionate and unreasonable as to violate due process.


St. Louis, Iron Mountain & S. Ry. Co. v. Williams, 251 U.S. 63 (1919)