Sunshine Anthracite Coal Co. v. Adkins
310 U.S. 381 (1940)

Annotate this Case

U.S. Supreme Court

Sunshine Anthracite Coal Co. v. Adkins, 310 U.S. 381 (1940)

Sunshine Anthracite Coal Co. v. Adkins

No. 804

Argued April 29, 1940

Decided May 20, 1940

310 U.S. 381

Syllabus

1. The 19 1/2% tax imposed by § 3(b) of the Bituminous Coal Conservation Act (1937) on sales of such coal by producers, "which would be subject to the application of the conditions and provisions of the code provided for in § 4, or of the provisions of § 4A," applies to producers who are not members of the code, although under § 4, the provisions of the code are for code members only. P. 310 U. S. 391.

A contrary construction would read the 19 1/2% tax out of the Act, (since, by § 3(b), code members are exempt from it); the essential sanction of the Act would then disappear, and its effectiveness would be seriously impaired. Section 4 is made expressly applicable "only to matters and transactions in or directly affecting interstate commerce." It seems plain that the tax was intended to apply only to those sales by noncode members which "would be" subject to regulation under § 4. P. 310 U. S. 392.

2. The constitutionality of the Act is upheld over the contentions that the 19 1/2% tax is not a tax, but a penalty; that Congress lacks power to fix minimum prices for bituminous coal sold in interstate commerce; that there has been an invalid delegation of legislative and judicial power, and that the division of bituminous coal into code and noncode classes is improper. Pp. 310 U. S. 393et seq.

3. The taxing power of Congress may be used as a sanction for the exercise of another granted power. P. 310 U. S. 393.

4. The regulatory provisions of the Act are within the commerce power; they apply only to sales or transactions in, or intimately affecting, interstate commerce. P. 310 U. S. 393.

5. Price control is a means available to Congress for the protection and promotion of the public economy. P. 310 U. S. 394.

Courts are not concerned with the wisdom, policy, or appropriateness of this legislation. But the state of the bituminous coal industry and its history and public importance plainly support the judgment of Congress that price-fixing and the elimination of unfair competitive practices were appropriate methods for prevention of the financial ruin, low wages, poor working conditions, strikes, and disruption of the channels of trade which followed in the wake of the demoralized price structures. P. 310 U. S. 394.

Page 310 U. S. 382

6. Congress may modify the prohibitions of the Sherman Act by placing the machinery of price-fixing in the hands of public agencies. P. 310 U. S. 396.

7. Congress may single out a particular industry and remove as to it the penalties of the Sherman Act . P. 310 U. S. 396.

8. The commerce clause empowers Congress to stabilize an interstate industry through a process of price-fixing which safeguards the public interest by placing price control in the hands of its administrative representative. P. 310 U. S. 396.

9. The standards specified by § 4, II(c) of the Bituminous Coal Act to control the Commission in fixing maximum and minimum prices binding code members, are adequate, and there is no invalid delegation of legislative power. P. 310 U. S. 397.

10. In the matter of price-making, code members are subordinated by the Act to the Commission, so that there is no delegation of legislative authority to the industry. P. 310 U. S. 399.

11. The definition of bituminous coal in the Act, § 17(b), is adequate as a standard for the Commission's action in determining what coal is subject to the Act. P. 310 U. S. 399.

12. The Act makes no invalid delegation of judicial power to the Commission for determining whether a particular coal producer falls within its provisions, and it grants sufficient judicial review. P. 310 U. S. 400.

13. A contention that the Act, by classifying the coal as code and noncode and applying the 19 1/2% tax to the latter alone, violates the Fifth Amendment is rejected, since the procedural features satisfy due process, and the Fifth Amendment has no equal protection clause; nor is uniformity required by the commerce clause. P. 310 U. S. 400.

14. A judgment sustaining on review a determination by the Bituminous Coal Commission that a producer's coal is "bituminous" within the meaning of § 17(b) of the Bituminous Coal Conservation Act, thus subjecting him to the 19 1/2% tax laid on sales by producers who have not joined the code, is res judicata in a suit by the producer to enjoin the Commissioner of Internal Revenue from collecting the tax. P. 310 U. S. 401.

15. Where Congress has created a special administrative procedure for determining the status of persons and companies under a regulatory Act, and has prescribed a procedure satisfying due process, that remedy is exclusive. P. 310 U. S. 404.

Page 310 U. S. 383

16. In the circumstances of this case, appellant is not entitled to relief from payment of taxes accrued during the litigation since the date fixed by the decree below. P. 310 U. S. 404.

Affirmed.

Appeal from a decree of the District Court dismissing a bill to enjoin the collection of taxes. See also 31 F.Supp. 125 and 105 F.2d 559.

Page 310 U. S. 387

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