In the case of Henderson v. Carbondale Coal and Coke Company, the U.S. Supreme Court ruled in favor of Carbondale Coal and Coke Company, overturning a previous decision by the Pennsylvania Supreme Court. The dispute arose when Henderson claimed that he was entitled to royalties from coal mined on his property under an 1864 lease agreement with another company which had since been bought out by Carbondale Coal and Coke Company. However, the court found that there were no provisions in either the original lease or subsequent agreements for such payments to be made after ownership changed hands unless explicitly stated otherwise. Therefore, it held that Henderson's claim was invalid as he could not prove any legal right to these royalties under existing contracts or laws.

In the dissenting opinion for Henderson v. Carbondale Coal and Coke Company, it was argued that the majority's decision to uphold a Pennsylvania law requiring coal companies to pay miners in cash rather than company scrip was an overreach of judicial power. The dissenting justices believed that this issue should have been left up to individual contracts between employers and employees, not mandated by state law. They also expressed concern about the potential economic impact of such a ruling on coal companies, arguing that forcing them to pay in cash could lead to financial instability or even bankruptcy. Furthermore, they questioned whether this type of regulation truly fell within the scope of states' police powers as defined by previous court decisions.