Jewell Ridge Coal Corp. v. Mine Workers
Encyclopedia
Jewell Ridge Coal Corp. v. United Mine Workers of America, 325 U.S. 161
(1945) was a case decided by the Supreme Court of the United States
dealing with the compensation of mine workers for time spent traveling to work sites while underground.
The employer, Jewell Ridge, sought declaratory judgment
against its employee's union
to determine whether the time spent traveling underground by the coal miners between the portals of the employer's two bituminous coal
mines and the working faces was included in the compensable workweek under § 7 of the Fair Labor Standards Act
of 1938, 29 U.S.C. § 207(a). (Note: The Fair Labor Standards Act is now Chapter 8 of Title 29 of the United States Code
, abbreviated as § 8 of 29 U.S.C.)
, the Supreme Court affirmed the appellate court
's ruling, holding that underground travel time was compensable under the Act. Relying on the three elements of 'work' established in Tennessee Coal, Iron & R. Co. v. Muscoda Local No. 123 (1944), the court reasoned that underground traveling was considered compensable work because it (1) required physical and mental exertion that was (2) controlled and required by the employer (3) for the employer's benefit.
The court distinguished underground travel from typical above-ground commuting by non-miners, stating that once below ground the miner is subject to additional dangers. Furthermore, the court stated that the Fair Labors Standard Act supersedes any previous customs or agreements which excluded such travel time from the compensable work week.
argued that majority opinion invalidates or ignores collective bargaining agreements between unions and employers, which he said was contrary to the legislative intent
of the Fair Labor Standards Act.
’s former law partner and personal lawyer. Rehearing of the case was denied by the court on June 18, 1945. 325 U.S. 897
. However, despite this apparent conflict of interest
, Black lobbied the Court for a per curiam denial of the petition for rehearing. Justice Jackson
objected to a per curiam denial of rehearing and filed a concurring opinion, which disassociated himself from the ruling and, by implication, criticized Black for not addressing the conflict of interest. The infighting between Black and Jackson may also have played a role in the death of Harlan F. Stone two weeks before this ruling, and the nomination of Fred M. Vinson
to the Court instead of a current Associate Justice.
Jackson also criticized Black's alleged proposal of handing down the court's decision without waiting for the majority and dissenting opinions. Jackson claimed that Black's reasoning for this unorthodox proposal was to influence contract negotiations for the ongoing coal strike
, in an attempt to strengthen the coal miner's bargaining position. Jackson accused Black of simply trying to manipulate the court process to suit his own ideological agenda.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1945) was a case decided by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
dealing with the compensation of mine workers for time spent traveling to work sites while underground.
The employer, Jewell Ridge, sought declaratory judgment
Declaratory judgment
A declaratory judgment is a judgment of a court in a civil case which declares the rights, duties, or obligations of one or more parties in a dispute. A declaratory judgment is legally binding, but it does not order any action by a party. In this way, the declaratory judgment is like an action to...
against its employee's union
Trade union
A trade union, trades union or labor union is an organization of workers that have banded together to achieve common goals such as better working conditions. The trade union, through its leadership, bargains with the employer on behalf of union members and negotiates labour contracts with...
to determine whether the time spent traveling underground by the coal miners between the portals of the employer's two bituminous coal
Bituminous coal
Bituminous coal or black coal is a relatively soft coal containing a tarlike substance called bitumen. It is of higher quality than lignite coal but of poorer quality than Anthracite...
mines and the working faces was included in the compensable workweek under § 7 of the Fair Labor Standards Act
Fair Labor Standards Act
The Fair Labor Standards Act of 1938 is a federal statute of the United States. The FLSA established a national minimum wage, guaranteed 'time-and-a-half' for overtime in certain jobs, and prohibited most employment of minors in "oppressive child labor," a term that is defined in the statute...
of 1938, 29 U.S.C. § 207(a). (Note: The Fair Labor Standards Act is now Chapter 8 of Title 29 of the United States Code
United States Code
The Code of Laws of the United States of America is a compilation and codification of the general and permanent federal laws of the United States...
, abbreviated as § 8 of 29 U.S.C.)
Majority Opinion
In an opinion authored by Frank MurphyFrank Murphy
William Francis Murphy was a politician and jurist from Michigan. He served as First Assistant U.S. District Attorney, Eastern Michigan District , Recorder's Court Judge, Detroit . Mayor of Detroit , the last Governor-General of the Philippines , U.S...
, the Supreme Court affirmed the appellate court
Appellate court
An appellate court, commonly called an appeals court or court of appeals or appeal court , is any court of law that is empowered to hear an appeal of a trial court or other lower tribunal...
's ruling, holding that underground travel time was compensable under the Act. Relying on the three elements of 'work' established in Tennessee Coal, Iron & R. Co. v. Muscoda Local No. 123 (1944), the court reasoned that underground traveling was considered compensable work because it (1) required physical and mental exertion that was (2) controlled and required by the employer (3) for the employer's benefit.
The court distinguished underground travel from typical above-ground commuting by non-miners, stating that once below ground the miner is subject to additional dangers. Furthermore, the court stated that the Fair Labors Standard Act supersedes any previous customs or agreements which excluded such travel time from the compensable work week.
Dissenting Opinion
In his dissent, Justice JacksonRobert H. Jackson
Robert Houghwout Jackson was United States Attorney General and an Associate Justice of the United States Supreme Court . He was also the chief United States prosecutor at the Nuremberg Trials...
argued that majority opinion invalidates or ignores collective bargaining agreements between unions and employers, which he said was contrary to the legislative intent
Legislative intent
In law, the legislative intent of the legislature in enacting legislation may sometimes be considered by the judiciary when interpreting the law...
of the Fair Labor Standards Act.
Black-Jackson Feud
The coal company later filed a petition for rehearing on the grounds that the miners were represented by Crampton P. Harris, who was Justice BlackHugo Black
Hugo Lafayette Black was an American politician and jurist. A member of the Democratic Party, Black represented Alabama in the United States Senate from 1927 to 1937, and served as an Associate Justice of the Supreme Court of the United States from 1937 to 1971. Black was nominated to the Supreme...
’s former law partner and personal lawyer. Rehearing of the case was denied by the court on June 18, 1945. 325 U.S. 897
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
. However, despite this apparent conflict of interest
Conflict of interest
A conflict of interest occurs when an individual or organization is involved in multiple interests, one of which could possibly corrupt the motivation for an act in the other....
, Black lobbied the Court for a per curiam denial of the petition for rehearing. Justice Jackson
Robert H. Jackson
Robert Houghwout Jackson was United States Attorney General and an Associate Justice of the United States Supreme Court . He was also the chief United States prosecutor at the Nuremberg Trials...
objected to a per curiam denial of rehearing and filed a concurring opinion, which disassociated himself from the ruling and, by implication, criticized Black for not addressing the conflict of interest. The infighting between Black and Jackson may also have played a role in the death of Harlan F. Stone two weeks before this ruling, and the nomination of Fred M. Vinson
Fred M. Vinson
Frederick Moore Vinson served the United States in all three branches of government and was the most prominent member of the Vinson political family. In the legislative branch, he was an elected member of the United States House of Representatives from Louisa, Kentucky, for twelve years...
to the Court instead of a current Associate Justice.
Jackson also criticized Black's alleged proposal of handing down the court's decision without waiting for the majority and dissenting opinions. Jackson claimed that Black's reasoning for this unorthodox proposal was to influence contract negotiations for the ongoing coal strike
Strike action
Strike action, also called labour strike, on strike, greve , or simply strike, is a work stoppage caused by the mass refusal of employees to work. A strike usually takes place in response to employee grievances. Strikes became important during the industrial revolution, when mass labour became...
, in an attempt to strengthen the coal miner's bargaining position. Jackson accused Black of simply trying to manipulate the court process to suit his own ideological agenda.
See also
- List of United States Supreme Court cases, volume 325
- Black-Jackson Feud
Further reading
- St. Antoine, Theodore J.Theodore J. St. AntoineTheodore J. St. Antoine is an American lawyer and legal scholar. He has served on the faculty of the University of Michigan Law School since 1965 and is currently the James E. and Sarah A. Degan Professor Emeritus of Law at the school. St. Antoine served as dean of the Law School from 1971 to...
, Justice Frank Murphy and American labor law, Michigan Law ReviewMichigan Law ReviewThe Michigan Law Review is an American law reviews established in 1902, after Gustavus Ohlinger, a student in the Law Department of the University of Michigan, approached the Dean with a proposal for a law journal. The Michigan Law Review was originally intended as a forum in which the faculty of...
{100 MLR 1900, June 1, 2002).
External links
- 325 U.S. 161 Full text of the opinion on Findlaw.com.