Plymouth Coal Co. v. Pennsylvania
34 S. Ct. 359, 232 U.S. 531, 1914 U.S. LEXIS 1384 (1914)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A state may, in the exercise of its police power, require owners of adjoining coal mines to leave a barrier pillar of coal for safety and delegate the authority to determine the pillar's width to an administrative tribunal of experts without violating the Due Process Clause of the Fourteenth Amendment.
Facts:
- Pennsylvania enacted the Anthracite Mine Act to ensure the health and safety of coal miners.
- The Act required owners of adjoining coal properties to leave a 'barrier pillar' of coal between their mines to prevent one from flooding the other if abandoned.
- The Act specified that the width of this pillar was to be determined by a tribunal consisting of the engineers from the adjoining properties and the district mine inspector.
- Plymouth Coal Co. and the People's Coal Co. operated adjoining coal mines.
- The district mine inspector notified Plymouth Coal Co. of the need to determine the barrier pillar width between its mine and the People's Coal Co. mine.
- Plymouth Coal Co. refused to cooperate or appoint an engineer to the tribunal, arguing that the statutory method for determining the pillar's width was unconstitutional.
Procedural Posture:
- The Commonwealth of Pennsylvania, on behalf of the mine inspector, filed a bill for an injunction against Plymouth Coal Co. in the Court of Common Pleas of Luzerne County, a state trial court.
- The trial court granted the injunction, requiring Plymouth Coal Co. to leave a barrier pillar and participate in the statutory process to determine its width.
- Plymouth Coal Co., as appellant, appealed the decision to the Supreme Court of Pennsylvania, the state's highest court.
- The Supreme Court of Pennsylvania affirmed the trial court's decree.
- Plymouth Coal Co., as plaintiff in error, brought the case to the Supreme Court of the United States on a writ of error.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a state statute requiring adjoining coal mine owners to leave a barrier pillar of a width to be determined by an administrative tribunal, composed of a state inspector and engineers from the adjoining properties, constitute a taking of property without due process of law in violation of the Fourteenth Amendment?
Opinions:
Majority - Justice Pitney
No, the state statute does not constitute a taking of property without due process of law. The state's police power clearly extends to regulating dangerous industries like coal mining for public safety. It is a well-established and constitutional practice for a legislature to set a general rule and delegate the authority to determine its specific application to an administrative body of experts, especially when technical details vary by location. The statute implicitly requires a fair hearing, and any arbitrary action by the administrative tribunal would be subject to judicial review, which satisfies the requirements of due process. Plymouth Coal Co.'s objections are hypothetical, as it has not participated in the process and therefore cannot demonstrate that the law as applied to it is unconstitutional.
Analysis:
This case is a foundational administrative law decision that affirms the constitutionality of delegating quasi-legislative authority to expert administrative bodies. It establishes that due process does not require a full judicial trial for every government determination affecting property, particularly in the context of public safety regulation. The decision solidifies the principle that legislative bodies can create specialized tribunals to apply general rules to specific, technical situations. It also reinforces the standing requirement that a party challenging a statute must demonstrate actual or imminent injury from the allegedly unconstitutional feature, rather than raising purely hypothetical objections.
