''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 The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. Federal tribunals in the United States, federal court cases, and over Stat ...

dealing with the compensation of mine workers for time spent traveling to work sites while underground.

Facts

The employer, Jewell Ridge, sought

declaratory judgment A declaratory judgment, also called a declaration, is the legal determination of a court that resolves legal uncertainty for the litigants. It is a form of legally binding preventive by which a party involved in an actual or possible legal ma ...

against its employee's

union Union commonly refers to: * Trade union, an organization of workers * Union (set theory), in mathematics, a fundamental operation on sets Union may also refer to: Arts and entertainment Music * Union (band), an American rock group ** ''Un ...

to determine whether the time spent traveling underground by the

coal miners People have worked as coal miners for centuries, but they became increasingly important during the Industrial revolution when coal was burnt on a large scale to fuel stationary and locomotive engines and heat buildings. Owing to coal's strategic ro ...

between the portals of the employer's two

bituminous coal Bituminous coal, or black coal, is a type of coal containing a tar-like substance called bitumen or asphalt. Its coloration can be black or sometimes dark brown; often there are well-defined bands of bright and dull material within the seams. It ...

mines and the working faces was included in the compensable workweek under § 7 of the

Fair Labor Standards Act The Fair Labor Standards Act of 1938 (FLSA) is a United States labor law that creates the right to a minimum wage, and " time-and-a-half" overtime pay when people work over forty hours a week. It also prohibits employment of minors in "oppr ...

of 1938,

29 U.S.C. Title 29 of the United States Code is a code that outlines labor regulations in the United States.255(A) Code Chapters Title 29 has 35 chapters: * : Labor Statistics * : Women's Bureau * . Children's Bureau (Transferred) * . National Trade U ...

§ 207(a).

Judgment

Majority opinion

In an opinion authored by Justice

Frank Murphy William Francis Murphy (April 13, 1890July 19, 1949) was an American politician, lawyer and jurist from Michigan. He was a Democrat who was named to the Supreme Court of the United States in 1940 after a political career that included serving ...

, the

Supreme Court A supreme court is the highest court within the hierarchy of courts in most legal jurisdictions. Other descriptions for such courts include court of last resort, apex court, and high (or final) court of appeal. Broadly speaking, the decisions of ...

affirmed the

appellate court A court of appeals, also called a court of appeal, appellate court, appeal court, court of second instance or second instance court, is any court of law that is empowered to hear an appeal of a trial court or other lower tribunal. In much of ...

's ruling, holding that underground travel time was compensable under the Act. Relying on the three elements of 'work' established in '' Tennessee Coal, Iron & Railroad 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 Jackson argued that majority opinion invalidates or ignores

collective bargaining agreements Collective bargaining is a process of negotiation between employers and a group of employees aimed at agreements to regulate working salaries, working conditions, benefits, and other aspects of workers' compensation and rights for workers. The i ...

between unions and employers, which he said was contrary to the

legislative intent In law, the legislative intent of the legislature in enacting legislation may sometimes be considered by the judiciary to interpret the law (see judicial interpretation). The judiciary may attempt to assess legislative intent where legislation ...

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 Black’s former law partner and personal lawyer. Rehearing of the case was denied by the court on June 18, 1945. However, despite this apparent

conflict of interest A conflict of interest (COI) is a situation in which a person or organization is involved in multiple interests, financial or otherwise, and serving one interest could involve working against another. Typically, this relates to situations i ...

, Black lobbied the Court for a

per curiam In law, a ''per curiam'' decision (or opinion) is a ruling issued by an appellate court of multiple judges in which the decision rendered is made by the court (or at least, a majority of the court) acting collectively (and typically, though not ...

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 Frederick "Fred" Moore Vinson (January 22, 1890 – September 8, 1953) was an American attorney and politician who served as the 13th chief justice of the United States from 1946 until his death in 1953. Vinson was one of the few Americans to ...

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 may refer to: People * Strike (surname) Physical confrontation or removal *Strike (attack), attack with an inanimate object or a part of the human body intended to cause harm *Airstrike, military strike by air forces on either a suspected ...

, 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.

Notes

References

External links

* * {{caselaw source , case = ''Jewell Ridge Coal Corp. v. United Mine Workers of America'', {{ussc, 325, 161, 1945, el=no , courtlistener =https://www.courtlistener.com/opinion/104136/jewell-ridge-corp-v-local/ , findlaw = https://caselaw.findlaw.com/us-supreme-court/325/161.html , googlescholar = https://scholar.google.com/scholar_case?case=10264368062866893645 , justia =https://supreme.justia.com/cases/federal/us/325/161/case.html , loc =http://cdn.loc.gov/service/ll/usrep/usrep325/usrep325161/usrep325161.pdf , openjurist =https://openjurist.org/325/us/161 1945 in United States case law United States Supreme Court cases United States Supreme Court cases of the Stone Court United States labor case law United Mine Workers of America litigation Coal mining in the United States Commuting