Yazoo & Mississippi Valley R. Co. v. Jackson Vinegar Co., 226 U.S. 217 (1912)
If a statute was constitutional in its application to a certain party, that party cannot challenge it for being unconstitutional in other applications.
The Yazoo & Mississippi Valley R.R. transported vinegar in the state of Mississippi for the Jackson Vinegar Co. Some of this vinegar was lost in transit, and Jackson notified the Railroad of the loss, which was quantified at $4.76. Railroads and other common carriers were required under Mississippi law to settle claims of less than $200 when they received notice of them, and a $25 penalty would be assessed against them if they failed to settle these claims within the appropriate time. Jackson received both damages and the penalty in a state court action when the railroad failed to promptly settle the claim. The railroad challenged the constitutionality of the state law by appealing directly to the Supreme Court, since no other state court had jurisdiction over the case.Opinions
- Willis Van Devanter (Author)
- Byron Raymond White
- Joseph McKenna
- Oliver Wendell Holmes, Jr.
- William Rufus Day
- Horace Harmon Lurton
- Charles Evans Hughes
- Joseph Rucker Lamar
- Mahlon Pitney
If a claim lacked merit or was improperly inflated, the state law might be unconstitutional. In this situation, it was constitutional because the evidence presented at trial showed that the plaintiff's claim was valid. Therefore, the law was properly applied to the defendant in the case, and it was not facially invalid because it was an appropriate way of encouraging efficient settlements of these claims. Even if a law might not always be constitutional, a defendant does not have standing to challenge it if it was valid as applied here.Case Commentary
Standing can be found only when the party bringing the claim would be affected by its result. It is not proper to litigate on behalf of speculative future interests of other parties.
U.S. Supreme CourtYazoo & Mississippi Valley R. Co. v. Jackson Vinegar Co., 226 U.S. 217 (1912)
Yazoo and Mississippi Valley Railroad
Company v. Jackson Vinegar Company
Submitted November 13, 1912
Decided December 2, 1912
226 U.S. 217
The statute of Mississippi imposing a penalty on common carriers for failure to settle claims for lost or damaged freight in shipment within the state within a reasonable specified period is not unconstitutional under the Fourteenth Amendment as depriving the carrier of its property without due process of law or as denying it the equal protection of the laws as to claimants presenting actual claims for amounts actually due.
It is within the police power of the state to provide by penalty for delay a reasonable incentive for prompt settlement without suit of just demands of a class admitting of special legislative treatment, in this case of claims against common carriers for damage to goods shipped between two points within the state.
This Court deals with the case in hand, and not with imaginary ones, and if a state statute is constitutional as against the class to which the party attacking it belongs, it will not consider whether the same statute might be unconstitutional as applied to other classes not before the court.
Quaere, and not now to be decided, whether the statute now sustained as constitutional as against the party attacking it would be void in toto if unconstitutional as against other classes who have not yet attacked it.
The facts, which involve the constitutionality of a statute of Mississippi imposing penalties on common carriers for failure to settle claims for damage to goods in shipment within the state, are stated in the opinion.