McLean v. Arkansas
Headline: Arkansas law requiring coal to be weighed before screening is upheld, allowing the State to punish mine operators who pay miners only for screened coal and protecting miners’ wages at larger mines.
Holding: The Court affirmed the conviction and held that Arkansas’s law requiring coal be weighed before screening is a valid exercise of the State’s power because it reasonably protects miners’ pay and industry safety.
- Allows states to require coal be weighed before screening to protect miners’ pay.
- Permits criminal penalties against mine operators who underpay miners by using screens.
- Supports state regulation of mining practices for worker protection on larger operations.
Summary
Background
A Missouri corporation operating a coal mine in Arkansas and its managing agent were convicted under an Arkansas law that forbids passing mined coal over a screen before the coal is weighed and credited to the miner. The company employed more than ten men and had contracts to pay miners only for the coal that passed over a screen; miners like W. H. Dempsey received nothing for coal that passed through the screen. The case was tried on an agreed statement of facts and the sole question presented was whether the Arkansas statute was constitutional.
Reasoning
The main question was whether the law unlawfully interfered with the miners’ right to make contracts or denied equal treatment by applying only to mines with ten or more men. The Court said the right to contract is not absolute and that a State may reasonably limit contracts to protect public health, safety, or welfare. Citing prior decisions and an industry inquiry showing disputes over screens and pay, the Court concluded the law reasonably aimed to ensure miners are honestly paid and to reduce conflict between operators and workers. The classification limiting the law to larger mines was also held reasonable because very small or experimental mines need not be regulated the same way.
Real world impact
The ruling lets Arkansas enforce weighing rules and criminal penalties against operators who pay only for screened coal at larger mines. It upholds a state’s power to adopt workplace rules meant to protect workers’ pay and industry fairness. The decision affirms the state court’s judgment and is not a statement that similar laws in other settings must always be upheld.
Dissents or concurrances
Two Justices, Brewer and Peckham, dissented, disagreeing with the majority’s conclusion on the statute’s validity.
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