Matthew Addy Co. v. United States

Background

A coal middleman company that bought coal on July 31, 1917 from a West Virginia producer and later sold it in August and September was convicted for taking a margin above prices the President had fixed that month. The Lever Act gave the President wartime authority to set coal prices and the Fuel Administrator issued related instructions. The company sold coal bought before the President’s August 23, 1917 order and the Government prosecuted for violating the new jobber margin limit of 15 cents per ton.

Reasoning

The main question was whether the President’s August price order applied to sales that were part of transactions begun before that date. The Court said criminal rules must be read strictly and should not be applied retroactively unless Congress clearly required it. The Court noted that many coal supplies were under earlier contracts and that administrators had allowed prior contracts to stand. Given those facts and ordinary rules of interpretation, the Court concluded the August 23 order did not reach the sales at issue. The Justices reversed the convictions and avoided deciding whether Congress could force post‑sale prices without compensation.

Real world impact

The decision protects sellers who bought coal before the presidential price order from retroactive criminal penalties for selling at higher prices. It narrows the immediate reach of the wartime price order and leaves open broader questions about the Government’s authority to fix prices in other situations. The case was resolved narrowly and sent back to the lower court for further proceedings consistent with the opinion.