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Lindsley v. Natural Carbonic Gas Co.

Supreme Court of the United States · 1911 · Constitutional Law

Constitutional LawDue ProcessEqual ProtectionPolice PowerFourteenth Amendmentdue processequal protectionrational basis

Facts

The challenged New York provision, as construed by the state's highest court, did not absolutely forbid the specified pumping activity. Instead, it applied only when mineral waters were drawn from a common underground source extending beneath multiple owners' lands, and only when the draft was unreasonable or wasteful so as to injure others with a coequal right to draw from that source. The statute addressed a practice in which owners bored or drilled wells into porous rock and pumped the commingled mineral waters and carbonic acid gas in order to collect and sell the gas separately, a practice the opinion describes as generally causing excessive depletion of the common supply and waste of the waters. The plaintiff argued that the statute deprived property without due process, denied equal protection through arbitrary classifications, and was invalid because of a state-law ruling placing on the operator the burden of showing that the statutory exception applied.

Issue

Whether the New York statute, as construed by the New York Court of Appeals, violated the Fourteenth Amendment by depriving affected owners of property without due process of law, denying them equal protection through arbitrary classification, or creating an unconstitutional prima facie presumption in enforcement proceedings. The Court also had to assess the statute based on the state court's limiting construction rather than on an absolute reading of the text.

Rule

A state may regulate the exercise of coequal rights in a common underground supply to prevent waste and protect the rights of all interested owners without effecting a deprivation of property without due process. Under equal protection, a classification in a police law is invalid only when it has no reasonable basis and is therefore purely arbitrary; if any state of facts reasonably can be conceived to sustain it, that state of facts must be assumed, and the challenger bears the burden of proving arbitrariness. A legislative rule making proof of one fact prima facie evidence of another is valid if there is a rational connection between the proved and presumed facts and the party is not denied a fair opportunity to rebut and make a full defense.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Arkansas, several landowners in Hot Springs sit above a single porous limestone formation containing geothermal water and dissolved helium. A state statute, as construed by the state's highest court, applies only when an operator's extraction from that common formation is unreasonable or wasteful and injures neighboring owners with the same right of access; it bars only extraction designed to separate and sell the helium while discarding large amounts of heated water.

A drilling company argues the statute violates due process because it interferes with its property right to draw from beneath its own land. What is the strongest response?

Explanation. The majority upheld regulation of extraction from a common underground supply when the state court had limited the law to unreasonable or wasteful drafts that injure other proprietors sharing coequal rights. Such a law does not take away the owner's right to tap the source altogether; it regulates the exercise of that right to conserve the common resource and protect all interested owners. That is a permissible exercise of police power consistent with due process. (Derived from Lindsley v. Natural Carbonic Gas Co. (1911).)