## Facts

- Jackson Vinegar Company shipped vinegar intrastate in Mississippi via Yazoo & Mississippi Valley Railroad Company, a common carrier.
- Part of the shipment was lost or damaged.
- Jackson Vinegar gave written notice of its claim to the carrier’s destination agent, stating damages of $4.76.
- Mississippi law required common carriers to settle written claims for lost or damaged intrastate freight within 60 days (or 90 days if multiple carriers handled the freight) and imposed $25 “damages” in addition to actual damages for failure to settle; the statute applied only when the amount claimed was $200 or less.
- The railroad did not settle within 60 days.
- Jackson Vinegar sued for $4.76 actual damages plus the $25 statutory amount; the trier of fact found actual damages in the exact amount stated in the notice.
- Mississippi courts awarded Jackson Vinegar the actual damages and the statutory $25; the railroad sought review in the U.S. Supreme Court, asserting Fourteenth Amendment violations.

## Issues

1. Whether Mississippi’s fixed $25 penalty for failing to timely settle small intrastate freight loss/damage claims violates due process or equal protection under the Fourteenth Amendment when applied to a claim ultimately found valid and accurately stated.
2. Whether a carrier may attack the statute based on hypothetical applications to unfounded, excessive, or disputed claims not presented by the carrier’s own case.

## Decision

- The Court affirmed the judgment awarding $4.76 actual damages plus the $25 statutory amount.
- As applied to a claim that was timely noticed, accurately stated, and ultimately proven due, the statute did not violate due process or equal protection.
- The Court declined to consider hypothetical scenarios in which the statute might operate oppressively, limiting review to the case before it.
- The Court expressly left open whether the statute could be invalid in its entirety if unconstitutional as applied to other, nonpresented classes of cases.

## Legal Principles

- A state may regulate intrastate common carriers and impose reasonable penalties to encourage prompt payment of small, valid freight loss/damage claims.
- Constitutional review generally addresses the statute’s operation on the party before the Court; a litigant cannot invalidate a statute by relying on imagined unconstitutional applications to others.
- A classification targeting common carriers may satisfy equal protection when it addresses a distinct problem associated with that class and is not arbitrary.
- A fixed penalty tied to failure to settle a claim that proves valid is not, on that record, an arbitrary deprivation of property without due process.

## Conclusion

The Court upheld Mississippi’s $25 penalty scheme as a permissible regulation of intrastate common carriers when imposed for failure to timely settle a small, just claim, and it refused to entertain facial invalidation arguments based on hypothetical, nonpresented applications.


Yazoo & Mississippi Valley R.R. Co. v. Jackson Vinegar Co., 226 U.S. 217 (1912)