Congress passed the Bituminous Coal Conservation Act (BCCA) to create a national commission of coal miners, coal producers, and private citizens to help regulate the coal mining industry by establishing standards for fair competition, production, wages, hours, and labor relations. The BCCA delegated to the commission the power to fix the minimum and maximum prices of coal at every mine in the United States. Additionally, the labor relations provisions of the BCCA gave coal mine employees the right to organize and enter into collective bargaining agreements in all states. Although compliance with the BCCA was purely voluntary, Congress encouraged compliance by rewarding participating coal mines with a tax rebate for abiding by the BCCA’s provisions. Carter (plaintiff) sued his own company, Carter Coal Co. (defendant) to enjoin it from paying the required tax for noncompliance under the BCCA.