In the case of Simmons Creek Coal Company v. Doran, 1891, the U.S. Supreme Court was tasked with determining whether a West Virginia law that required coal companies to pay miners in legal currency rather than company-issued scrip was constitutional. The plaintiff, Simmons Creek Coal Company argued that this law violated their rights under the Fourteenth Amendment's due process clause and interfered with interstate commerce by regulating how they could conduct business transactions. However, the court ruled against them stating that states have broad powers to regulate businesses within their borders for public welfare purposes and found no violation of either federal commerce or due process protections in requiring payment of wages in lawful money instead of company scrip.

In the dissenting opinion for Simmons Creek Coal Company v. Doran, Justice Bradley argued that West Virginia's law requiring mining companies to pay miners in legal tender rather than company-issued scrip was unconstitutional. He believed it violated the Contract Clause of the Constitution by interfering with private contracts between employers and employees. According to him, if a miner willingly agreed to accept payment in scrip as part of his employment contract, then he should be allowed to do so without government interference. Furthermore, he contended that this law unfairly targeted mining companies while ignoring other industries where workers were paid in similar ways. Ultimately, Justice Bradley viewed this legislation as an overreach of state power into private contractual relationships.