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

Jackson Vinegar Co. (plaintiff) filed a small $4.76 damage claim with the railroad, Yazoo (defendant), after a shipment was lost or damaged. A Mississippi statute required railroads to settle claims under $200 within 60 days or pay a $25 penalty on top of actual damages. Yazoo missed the deadline, and Jackson sued for damages plus the penalty. Yazoo, having lost in the circuit court, appealed directly to the Supreme Court, conceding the statute was valid as applied to this small claim but arguing it would be unconstitutional as applied to an excessive claim a railroad might legitimately dispute — and that this hypothetical invalidity should void the statute entirely.

Whether federal courts are precluded from considering the constitutionality of a statute unless the statute is unconstitutional as applied to the facts of the actual case presented.