Lauff v. Pittsburgh Coal Co.

15 Pa. D. & C. 532, 1930 Pa. Dist. & Cnty. Dec. LEXIS 132
CourtPennsylvania Court of Common Pleas, Washington County
DecidedAugust 18, 1930
DocketNo. 201
StatusPublished

This text of 15 Pa. D. & C. 532 (Lauff v. Pittsburgh Coal Co.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Washington County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lauff v. Pittsburgh Coal Co., 15 Pa. D. & C. 532, 1930 Pa. Dist. & Cnty. Dec. LEXIS 132 (Pa. Super. Ct. 1930).

Opinion

Cummins, J.,

Plaintiff purchased what is called in common parlance the “surface” of a farm in this county. The Pittsburgh coal underlying this and other adjoining lands constitutes a bituminous mining field of defendant company. On its property, and not far from plaintiff’s land, defendant has opened a mine, erected a tipple and is mining coal. Near the pit mouth is the usual gob pile, where is piled the refuse from this mining operation. This gob pile became ignited, and the smoke and fumes therefrom have to some extent injured plaintiff’s crops and property, for which plaintiff seeks to recover in an action of trespass.

[533]*533Upon trial, it affirmatively appeared by plaintiff’s case that a gob pile is a necessary incident to a bituminous mine (but besides, this doubtless is a matter of common knowledge) ; that the gob pile in question became ignited from no fault of defendant company, but from spontaneous combustion; and that there is as yet no known practicable method of either extinguishing or controlling such fire. Plaintiff’s case was tried on the theory that to be entitled to recover, no proof of negligence was necessary. Negligence not having been established, a judgment of compulsory nonsuit was entered* a motion to take off which is now before the court in banc.

The actual damages suffered in this case may not be large, but the legal principles involved concern the whole bituminous mining industry of southwestern Pennsylvania, as well as the owners of property in these mining districts. In this industry millions of dollars have been invested and thousands of wage earners are employed. Mine openings are everywhere, and wherever mine openings, gob piles. Many of these gob piles have become ignited by spontaneous combustion; and, as yet, there is no practicable known means of either controlling or extinguishing such fires. These fires are volcanic in nature, i. e., internal, not external. The residue from them is the “red dog” of which many of the secondary roads of western Pennsylvania have been and are now being constructed. In almost all such cases some damage to property results, yet few suits have been instituted; and, although some of our authorities closely approach it, in no case, so far as we know, have the relative rights of the parties involved been directly passed upon by either of our appellate courts. This case, therefore, calls for a most careful consideration of the basic principles applicable.

We have, of course, the general rule expressed in the oft-quoted maxim, sometimes referred to as the “golden rule” in business, sic utere tuo ut alienum non Isedas; one must use his own land so as not to injure that of another; otherwise he is liable in damages.

To this general rule we have the equally well-known exception as restated by Mr. Justice Clark in Pennsylvania Coal Co. v. Sanderson, 113 Pa. 126, 146: “Every man has the right to the natural use and enjoyment of his own property, and if whilst lawfully in such use and enjoyment, without negligence or malice on his part, an unavoidable loss occurs to his neighbor, it is damnum absque injuria, for the rightful use of one’s own land may cause damage to another, without any legal wrong.” •

Mr. Chief Justice Mitchell, using quite similar language, in Strauss v. Allentown, 215 Pa. 96, 98, states the exception thus: “Every man has the right to the natural, proper and profitable use of his own land, and if in the course of such use without negligence, unavoidable loss, is brought upon his neighbor, it is damnum absque injuria. This is the universal rule of the common law, and nowhere is it more strictly enforced than in Pennsylvania.”

Again, in the late case of Beecher et ux. v. Dull et al., 294 Pa. 17, 20, Mr. Justice Frazer, in speaking of the two classes of cases arising out of this general rule and the exception thereto, more clearly defines the scope of each when he says: “The former class of cases [arising out of the application of the exception] applies the rule that damages resulting to another from a natural and lawful use by a person of his own premises, are, in the absence of malice or negligence, damages without remedy, while the latter [those arising out of the general rule and not within the scope of the exception] adopts the common law principle that one must so use his property as not to injure that of another. Cases necessarily arise where these two opposing rules conflict, and when this occurs the right to use one’s own property must prevail, pro[534]*534viding the resulting damage to another [a] cannot be avoided, or [b] only at such expense as would be practically prohibitive to a person in the enjoyment of his own land.”

It is true that it has been repeatedly said that the principle involved in this exception should never be extended, but the application of a principle to a new set of facts falling within its scope, does not constitute an extension of the legal principle or rule itself. To hold otherwise would destroy the basis of the whole of our common law, which consists not of concrete cases, but of the principles therein established.

From the application of this general rule of sic utere hue uh alienwm, non Isedas and the exception thereto under consideration, we have two distinct and well-defined groups of eases involving claims for damages for injury to real property resulting from industrial operations on adjoining lands: First, where the industry is either not the natural use and development of the property whereon located, or if so, the injury resulting can be avoided at a reasonable expense, in which cases proof alone of the injury will support a recovery, of which class Evans v. Fertilizing Co., 160 Pa. 209, Kent v. General Chemical Co., 285 Pa. 34, and McCune v. Pittsburgh & B. Coal Co., 238 Pa. 83, are examples; and, second, that group of cases where the act or use causing the injury complained of comes within the scope or limits of the exception to the general rule as above defined, in which case plaintiff to be entitled to recover must not only allege, but must prove, that the injury complained of was either the result of negligence or malice: Harvey v. Coal Co., 201 Pa. 63, 69; Elder v. Lykens Valley Coal Co., 157 Pa. 490, 497; Hindson v. Maride, 171 Pa. 138, 143; Collins v. Chartiers Valley Gas Co., 131 Pa. 143, 160; Vautier v. Atlantic Refining Co., 231 Pa. 8, 13; Robb v. Carnegie Bros. & Co., 145 Pa. 324, 340; D. & H. Canal Co. v. Goldstein, 125 Pa. 246, 257; Wheatley v. Baugh, 25 Pa. 528; Haldeman v. Bruckart, 45 Pa. 514; Pennsylvania Coal Co. v. Sanderson, 113 Pa. 126; Strauss v. Allentown, 215 Pa. 96, 99; Rielly v. Stephenson, 222 Pa. 252, 256; Tess v. Charleroi Home Building Co., 96 Pa. Superior Ct. 505, 509; Alexander v. Wilkes-Barre Anthracite Coal Co., 254 Pa. 1, 6.

In the first of these two groups of cases, the cause of action usually consists in the maintenance of a nuisance; while in the second, it usually consists of negligence, negligent operation or use. As between a coal operator and an individual owner, of surface, an act in connection with or a use of land cannot, however, both fall within the exception and at the same time constitute an actionable private nuisance; it cannot be both damnum absque injuria and at the same time constitute a tort or wrong.

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Bluebook (online)
15 Pa. D. & C. 532, 1930 Pa. Dist. & Cnty. Dec. LEXIS 132, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lauff-v-pittsburgh-coal-co-pactcomplwashin-1930.