Jewell Ridge Coal Corp. v. United Mine Workers of America

Last updated
Jewell Ridge Coal Corp. v. United Mine Workers of America
Seal of the United States Supreme Court.svg
Argued March 9, 1945
Decided May 7, 1945
Full case nameJewell Ridge Coal Corporation v. Local No. 6167, United Mine Workers Of America, et al.
Citations325 U.S. 161 ( more )
65 S. Ct. 1063; 89 L. Ed. 1534; 1945 U.S. LEXIS 2689
Case history
Prior53 F. Supp. 935 (W.D. Va. 1944), reversed, 145 F.2d 10 (4th Cir. 1944); cert. granted, 323 U.S. 707(1945).
SubsequentPetition for rehearing denied on June 18, 1945, 325 U.S. 897 (1945).
Holding
The underground travel time of coal miners was considered compensable work time under § 7(a) of the Fair Labor Standards Act of 1938, 29 U.S.C. § 207(a).
Court membership
Chief Justice
Harlan F. Stone
Associate Justices
Owen Roberts  · Hugo Black
Stanley F. Reed  · Felix Frankfurter
William O. Douglas  · Frank Murphy
Robert H. Jackson  · Wiley B. Rutledge
Case opinions
MajorityMurphy, joined by Black, Reed, Douglas, Rutledge
DissentJackson, joined by Stone, Roberts, Frankfurter
Laws applied
Fair Labor Standards Act, § 7(a), 29 U.S.C. § 207(a)

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. [1]

Contents

Facts

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). [2]

Judgment

Majority opinion

In an opinion authored by Justice Frank Murphy, 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 & Railroad Co. v. Muscoda Local No. 123 (1944), [3] 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 between unions and employers, which he said was contrary to the legislative intent 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. [4] 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. [5]

See also

Notes

  1. Jewell Ridge Coal Corp. v. United Mine Workers of America, 325 U.S. 161 (1945).
  2. Note: The Fair Labor Standards Act is now Chapter 8 of Title 29 of the United States Code, abbreviated as Ch. 8 of 29 U.S.C.
  3. Tennessee Coal, Iron & Railroad Co. v. Muscoda Local No. 123 , 321 U.S. 590 (1944).
  4. Jewell Ridge Coal Corp. v. United Mine Workers of America, 325 U.S. 897 (1945).
  5. Hutchison, Dennis J. (1988). "The Black–Jackson Feud". Sup. Ct. Rev. 1988: 203–243 [pp. 207–209]. JSTOR   3109625.

Related Research Articles

<span class="mw-page-title-main">Robert H. Jackson</span> US Supreme Court justice from 1941 to 1954

Robert Houghwout Jackson was an American lawyer, jurist, and politician who served as an Associate Justice of the U.S. Supreme Court from 1941 until his death in 1954. He had previously served as United States Solicitor General and United States Attorney General, and is the only person to have held all three of those offices. Jackson was also notable for his work as Chief United States Prosecutor at the Nuremberg trials of Nazi war criminals following World War II.

<span class="mw-page-title-main">Coal mining</span> Process of getting coal out of the ground

Coal mining is the process of extracting coal from the ground. Coal is valued for its energy content and since the 1880s has been widely used to generate electricity. Steel and cement industries use coal as a fuel for extraction of iron from iron ore and for cement production. In the United Kingdom and South Africa, a coal mine and its structures are a colliery, a coal mine is called a 'pit', and the above-ground structures are a 'pit head'. In Australia, "colliery" generally refers to an underground coal mine.

<span class="mw-page-title-main">John L. Lewis</span> American miner and labor leader

John Llewellyn Lewis was an American leader of organized labor who served as president of the United Mine Workers of America (UMW) from 1920 to 1960. A major player in the history of coal mining, he was the driving force behind the founding of the Congress of Industrial Organizations (CIO), which established the United Steel Workers of America and helped organize millions of other industrial workers in the 1930s, during the Great Depression. After resigning as head of the CIO in 1941, Lewis took the United Mine Workers out of the CIO in 1942 and in 1944 took the union into the American Federation of Labor (AFL).

<span class="mw-page-title-main">United Mine Workers of America</span> North American labor union

The United Mine Workers of America is a North American labor union best known for representing coal miners. Today, the Union also represents health care workers, truck drivers, manufacturing workers and public employees in the United States and Canada. Although its main focus has always been on workers and their rights, the UMW of today also advocates for better roads, schools, and universal health care. By 2014, coal mining had largely shifted to open pit mines in Wyoming, and there were only 60,000 active coal miners. The UMW was left with 35,000 members, of whom 20,000 were coal miners, chiefly in underground mines in Kentucky and West Virginia. However it was responsible for pensions and medical benefits for 40,000 retired miners, and for 50,000 spouses and dependents.

<span class="mw-page-title-main">Coal strike of 1902</span>

The Coal strike of 1902 was a strike by the United Mine Workers of America in the anthracite coalfields of eastern Pennsylvania. Miners struck for higher wages, shorter workdays, and the recognition of their union. The strike threatened to shut down the winter fuel supply to major American cities. At that time, residences were typically heated with anthracite or "hard" coal, which produces higher heat value and less smoke than "soft" or bituminous coal.

United States v. United Mine Workers of America, 330 U.S. 258 (1947), was a case in which the United States Supreme Court examined whether a trial court acted appropriately when it issued a restraining order to prevent a labor strike organized by coal miners. In an opinion written by Chief Justice Fred M. Vinson, the Court held that a restraining order and preliminary injunction prohibiting a strike did not violate the Clayton Antitrust Act or the Norris–La Guardia Act, that the trial court was authorized to punish the violation of its orders as criminal contempt, and that fines imposed by the trial court were warranted in the situation.

The Bituminous coal strike of 1977–1978 was a 110-day national coal strike in the United States led by the United Mine Workers of America, AFL–CIO. It began December 6, 1977, and ended on March 19, 1978. It is generally considered a successful union strike, although the contract was not beneficial to union members.

Arnold Ray Miller was a miner and labor activist who served as president of the United Mine Workers of America (UMWA), AFL–CIO, from 1972 to 1979. Winning as a reform candidate, he gained positive changes for the miners, including compensation for black lung disease. He had difficulty dealing with growing internal union opposition. His last two years as president were particularly tumultuous and he suffered two heart attacks, finally resigning in November 1979 with the title of "president emeritus for life".

Carter v. Carter Coal Company, 298 U.S. 238 (1936), is a United States Supreme Court decision interpreting the Commerce Clause of the United States Constitution, which permits the United States Congress to "regulate Commerce... among the several States." Specifically, it analyzes the extent of Congress’ power, according to the Commerce Clause, looking at whether or not they have the right to regulate manufacturing.

United Mine Workers of America v. Gibbs, 383 U.S. 715 (1966), was a case in which the Supreme Court of the United States held that in order for a United States district court to have pendent jurisdiction over a state-law cause of action, state and federal claims must arise from the same "common nucleus of operative fact" and the plaintiff must expect to try them all at once. This case was decided before the existence of the current supplemental jurisdiction statute, 28 U.S.C. § 1367.

<span class="mw-page-title-main">Harry S. Truman Supreme Court candidates</span>

During his two terms in office, President Harry S. Truman appointed four members of the Supreme Court of the United States: Chief Justice Fred M. Vinson, Associate Justice Harold Burton, Associate Justice Tom C. Clark, and Associate Justice Sherman Minton.

Mining in the United States has been active since the beginning of colonial times, but became a major industry in the 19th century with a number of new mineral discoveries causing a series of mining rushes. In 2015, the value of coal, metals, and industrial minerals mined in the United States was US $109.6 billion. 158,000 workers were directly employed by the mining industry.

Tennessee Coal, Iron & Railroad Co. v. Muscoda Local No. 123, 321 U.S. 590 (1944), was an important decision of the United States Supreme Court with regard to the interpretation of the Fair Labor Standards Act (FLSA). This set a precedent for an expansive construction of the language of the FLSA.

National Labor Relations Board v. Fansteel Metallurgical Corporation, 306 U.S. 240 (1939), is a United States Supreme Court case on labor laws in which the Court held that the National Labor Relations Board had no authority to order an employer to reinstate workers fired after a sit-down strike, even if the employer's illegal actions triggered that strike.

<span class="mw-page-title-main">Knoxville Iron Company</span> United States historic place

The Knoxville Iron Company was an iron production and coal mining company that operated primarily in Knoxville, Tennessee, United States, and its vicinity, in the late 19th and 20th centuries. The company was Knoxville's first major post-Civil War manufacturing firm, and played a key role in bringing heavy industry and railroad facilities to the city. The company was also the first to conduct major coal mining operations in the lucrative coalfields of western Anderson County, and helped establish one of Knoxville's first residential neighborhoods, Mechanicsville, in the late 1860s.

The 1920 Alabama coal strike, or the Alabama miners' strike, was a statewide strike of the United Mine Workers of America against coal mine operators. The strike was marked by racial violence, and ended in significant defeat for the union and organized labor in Alabama.

Integrity Staffing Solutions, Inc. v. Busk, 574 U.S. 27 (2014), was a unanimous decision by the United States Supreme Court, ruling that time spent by workers waiting to undergo anti-employee theft security screenings is not "integral and indispensable" to their work, and thus not compensable under the Fair Labor Standards Act (FLSA). The Court delivered their ruling on December 9, 2014.

<span class="mw-page-title-main">2015 term opinions of the Supreme Court of the United States</span>

The 2015 term of the Supreme Court of the United States began October 5, 2015, and concluded October 2, 2016. The table below illustrates which opinion was filed by each justice in each case and which justices joined each opinion.

Friedrichs v. California Teachers Association, 578 U.S. ___ (2016), is a United States labor law case that came before the Supreme Court of the United States. At issue in the case was whether Abood v. Detroit Board of Education (1977) should be overruled, with public-sector "agency shop" arrangements invalidated under the First Amendment, and whether it violates the First Amendment to require that public employees affirmatively object to subsidizing nonchargeable speech by public-sector unions, rather than requiring employees to consent affirmatively to subsidizing such speech. Specifically, the case concerned public sector collective bargaining by the California Teachers Association, an affiliate of the National Education Association.

Cedar Point Nursery v. Hassid, 594 U.S. ___ (2021), was a United States Supreme Court case involving eminent domain and labor relations. In its decision, the Court held that a regulation made pursuant to the California Agricultural Labor Relations Act that required agricultural employers to allow labor organizers to regularly access their property for the purposes of union recruitment constituted a per se taking under the Fifth Amendment. Consequently, the regulation may not be enforced unless “just compensation” is provided to the employers.

References