Barrett v. Indiana

Background

A coal mine owner or operator was convicted in an Indiana circuit court for violating a state law that required entries where mine cars run to have at least two feet of clear space beside the tracks. The law applied to bituminous coal mines but expressly exempted certain block coal veins. The conviction was twice reviewed by the Indiana Supreme Court and affirmed, and the case reached this Court on the question whether the state statute violated the Fourteenth Amendment’s protections.

Reasoning

The central question was whether the width requirement was an unconstitutional invasion of liberty or an unfair classification between different kinds of mines. The Court explained that states may use their police power to regulate hazardous businesses like coal mining, and that courts may only strike down laws that are palpably arbitrary. Because mining is dangerous and the legislature had reason to believe a clear two-foot space would improve safety, the Court found the regulation reasonably related to protecting workers. The Court also accepted the state court’s findings that differences in the number of mines, output, and the depths at which block and bituminous coal are mined could justify treating them differently. For those reasons the Court upheld the statute and affirmed the conviction.

Real world impact

The decision allows Indiana to enforce the two-foot clear-space requirement in bituminous coal mines and confirms that mine operators and employers can be punished for failing to keep those spaces free of obstructions. Miners in covered mines gain a safety rule intended to give drivers a place to avoid collisions. The exemption for block coal veins remains in effect because the Court would not second-guess the legislature’s factual judgments about differences between coal types.