Madison v. Ducktown Sulphur, Copper & Iron Co.

Ducktown Sulphur, Copper & Iron Company (DSCI) (defendant) began operating a copper mine near Ducktown, Pennsylvania, in 1891. Tennessee Copper Company (TCC) (defendant) began operating a copper mine near Ducktown in 1900. In operating their plants, both companies reduced iron ore using roast piles. The process produced smoke that descended on surrounding areas. Between 1901 and 1903, W. M. Madison and other owners of small farms in the Ducktown area (the farmers) (plaintiffs) filed three suits against the companies for nuisance. The farmers, all of whom had owned their land before either company’s operations began, claimed that the smoke damaged their crops and prevented them from enjoying their land and their homes. The farmers sought injunctions preventing the companies’ smoke-producing operations and monetary damages for harm to crops and timber. The farmers’ land had an aggregate value of less than $1,000. In contrast, the companies were large mining and manufacturing businesses. Their properties were worth nearly $2 million, they provided half of the county’s taxable income, and they employed more than 10,000 locals. Stopping the smoke-producing operations would effectively require the businesses to close. In each of the three cases, the chancellor declined to grant the requested injunction, but the Tennessee Court of Chancery Appeals reversed, granting permanent injunctions. The companies appealed.