Pennsylvania Coal Co v Mahon is a 1922 decision of the United States Supreme Court, written by Justice Oliver Wendell Holmes, that created the modern doctrine of regulatory takings. Pennsylvanias Kohler Act barred coal mining that would cause the ground above to subside, which effectively nullified a mining right the coal company had specifically bargained for and retained by deed. The Supreme Court held that while property may be regulated to a certain extent, a regulation that goes too far in destroying the value of a property right is the equivalent of a taking of property, requiring just compensation under the Fifth Amendment even though the state never physically occupied the land. The case remains the origin point for the ongoing constitutional question of when regulation becomes a compensable taking.
Facts
Decision Year Decision Date HoldingA state regulation of property, such as Pennsylvania's Kohler Act barring subsurface coal mining that could cause surface subsidence, becomes a taking requiring just compensation under the Fourteenth Amendment's Due Process Clause once it goes too far in destroying the value of an established property right, even without a physical occupation of the land. 1 Current StatusNot overruled; the Supreme Court continues to cite Mahon as the origin of regulatory takings doctrine in later cases including Penn Central Transportation Co. v. New York City (1978) and Lucas v. South Carolina Coastal Council (1992). 1 Case Status
Case Status (category)Overruled (in whole or part) 1 FAQs
What is the significance of Pennsylvania Coal Co v Mahon?
It is the origin of the regulatory takings doctrine.
Decided December 11, 1922, the case held that a state regulation of property, such as Pennsylvania's Kohler Act barring subsurface coal mining that could cause surface subsidence, becomes a taking requiring compensation when it goes too far. The Supreme Court continues to cite Mahon as the origin of regulatory takings doctrine.
Was the Kohler Act upheld?
No, the Court held it went too far.
No. The Court held that the Kohler Act goes too far by restricting the right to mine anthracite coal to so great an extent as to violate the Fourteenth Amendment Due Process clause's protection of property.
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Sources
1. Pennsylvania Coal Co. v. Mahon (Wikipedia)
- Infobox: DecideDate = December 11 (1922)
- Infobox: ArgueDate = November 14 (1922)
Subsequent Case History section
Today, the Supreme Court quotes Justice Holmes in Mahon for the recognition of the invalidity of a government regulation that so severely burdens private property that it constitutes a taking under the Fifth Amendment
Holding #2 section, Kohler Act goes too far
The Kohler Act "goes too far" by restricting the right to mine anthracite coal to so great an extent as to violate the 14th Amendment Due Process clause's protection of property and contract rights by effectively nullifying those rights.
In Group: Regulatory Takings and Estates Cases, Introduction, sentences 1-3
Pennsylvania Coal Co. v. Mahon, 260 U.S. 393 (1922), was a case in which the Supreme Court of the United States held that whether a regulatory act constitutes a taking requiring compensation depends on the extent of diminution in the value of the property.
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