Yazoo & Mississippi Valley Railroad Co. v. Jackson Vinegar Co.

226 U.S. 217 (1912)

Facts

P shipped product with D. P's product was damaged and P gave notice of its claim in the manner prescribed, placing its damages at $4.76. D failed to settle within sixty days and sued to recover its damages and the $25 statutory penalty. The court found for P on both its damages and the imposition of the statutory penalty against D. The penalty came from a state statute that required D to settle all claims for lost or damaged freight which has been lost or damaged between two given points on the same line or system, within sixty days. A common carrier failing to settle such claims was be liable to the consignee for twenty-five dollars in damages in each case, in addition to actual damages, all of which may be recovered in the same suit provided that this section shall only apply when the amount claimed is two hundred dollars or less. D appealed to the Supreme Court claiming the statute was unconstitutional. D claims the Mississippi statute providing for the penalty is repugnant to the due process of law and equal protection clauses of the Fourteenth Amendment to the Constitution of the United States.