PENNSYLVANIA COAL COMPANY v. MAHON

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Case Basics
Docket No. 
549
Plaintiff in error 
Pennsylvania Coal Company
Defendant in error 
H.J. Mahon
Decided By 
Advocates
(argued the cause for the plantiff in error)
(argued the cause for the defendants in error)
Term:
Facts of the Case 

Pennsylvania Coal Co. entered an agreement with H.J. Mahon in 1878 to gain full rights to mine the coal located beneath his surface-level property. However in 1921 the state of Pennsylvania passed the Kohler Act, which prohibited miners from extracting below-surface coal that supported surface- level buildings. When Pennsylvania Coal notified Mahon that it would mine coal beneath his property, Mahon filed suit in the Court of Common Pleas to prohibit mining in accordance with the Kohler Act. The court denied his suit but the Supreme Court of Pennsylvania reversed and allowed the ban on mining. Pennsylvania Coal contended that the Takings Clause of the Fifth Amendment protected its contractual rights to the coal.

Question 

Did the Kohler Act restrict coal mining to an extent that violated the Takings Clause of the Fifth Amendment by depriving mine owners of coal without compensation?

Conclusion 

Yes. Justice Oliver Wendell Holmes delivered the opinion for an 8-1 court. The Court ruled that the Kohler Act violated the Takings Clause of the Fifth Amendment. The state exceeded its police powers by significantly diminishing the value of the land estates without having a strong public interest reason to do so. The Court reasoned that "if regulation goes too far it will be recognized as a taking." In this case, the Court held that "so far as private persons or communities have seen fit to take the risk of acquiring only surface rights, we cannot see that the fact that their risk has become a danger warrants the giving to them greater rights than they bought."

Cite this Page
PENNSYLVANIA COAL COMPANY v. MAHON. The Oyez Project at IIT Chicago-Kent College of Law. 25 November 2014. <http://www.oyez.org/cases/1901-1939/1922/1922_549>.
PENNSYLVANIA COAL COMPANY v. MAHON, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1901-1939/1922/1922_549 (last visited November 25, 2014).
"PENNSYLVANIA COAL COMPANY v. MAHON," The Oyez Project at IIT Chicago-Kent College of Law, accessed November 25, 2014, http://www.oyez.org/cases/1901-1939/1922/1922_549.