Plymouth Coal Co. v. Pennsylvania

Background

A Pennsylvania law aimed at anthracite coal mine safety applies to mines with more than ten workers and divides the coal region into inspection districts with a professional inspector for each. The statute requires owners of adjoining mines to leave barrier pillars of coal for worker safety, with the exact width to be determined by a tribunal of mine experts—engineers representing owners plus the district inspector. A mine owner challenged the method for fixing pillar width as uncertain and a taking of property without due process.

Reasoning

The Court addressed whether the statute’s process for fixing barrier pillars violates property rights. Citing the dangerous nature of mining and the State’s power to regulate safety, the Court accepted that authority can be delegated to an administrative tribunal. It relied on Pennsylvania courts’ interpretation that the tribunal consists of two engineers and the inspector, and found the statute reasonably read to require the inspector’s participation and allow majority decisions. The Court also noted implied requirements of notice and that judicial review would be available for arbitrary action. Because the claimant had notice and did not show arbitrary harm, the Court affirmed the lower judgment upholding the statute.

Real world impact

The decision leaves in place a process where mine inspectors and engineers set safety pillars, meaning mine owners must participate, often by supplying or hiring an engineer, and follow experts’ determinations. Enforcement typically occurs by injunction, and courts remain able to review arbitrary or unconstitutional action by the tribunal. This preserves state-administered, expert-driven safety rules for anthracite mines.