Pennsylvania Coal Company v. Mahon

PETITIONER: Pennsylvania Coal Company
RESPONDENT: H.J. Mahon
LOCATION:

DOCKET NO.: 549
DECIDED BY: Taft Court (1922)
LOWER COURT:

ARGUED: Nov 14, 1922
DECIDED: Dec 11, 1922

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?