Jewell Ridge Coal Corp. v. Local No. 6167, United Mine Workers
Headline: Underground travel in bituminous coal mines is ruled work and must be included in the Fair Labor Standards Act workweek, expanding hours that coal companies must count and pay.
Holding: The Court held that miners’ underground travel between portals and working faces in bituminous coal mines is compensable work under Section 7(a) of the Fair Labor Standards Act and must be included in the workweek.
- Requires coal operators to count and pay miners’ underground travel time as part of the workweek.
- May increase overtime pay obligations and potential back‑pay liabilities for mines.
- Overrides long‑standing industry customs and collective bargaining rules excluding travel time.
Summary
Background
A Virginia coal company that owned two bituminous mines sued its workers’ union to decide how to compute the miners’ workweek under the Fair Labor Standards Act. The company paid miners on a long-standing “face to face” basis, excluding time spent traveling underground from portals to working faces. The District Court accepted the industry practice; the Fourth Circuit reversed after this Court’s earlier iron‑ore decision was applied to the coal facts.
Reasoning
The Court asked whether underground travel in these coal mines is the kind of activity Congress meant to include in the compensable workweek. Relying on the earlier Tennessee Coal decision, the Court found three facts show travel is work here: the miners exert themselves physically or mentally while traveling; the employer controls and requires the travel (scheduled man trips, foremen, safety rules); and the travel is undertaken primarily to benefit the employer’s mining operations. The Court rejected industry custom and collective bargains that excluded travel time, saying the statute’s purpose is to guarantee compensation for all work covered by the Act.
Real world impact
The ruling requires coal operators to count portal‑to‑portal underground travel time as working time for overtime and related pay. The decision displaces long‑standing pay practices and may force changes in wage calculations, collective agreements, and payrolls. The judgment affirmed the lower court of appeals and therefore decides the legal question for the period in dispute.
Dissents or concurrances
A dissent stressed that the decision overrides long‑standing collective bargaining agreements, administrative interpretations, and wartime settlements, warning of major disruption to industry contracts and wage systems.
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