Zancanelli v. Central Coal & Coke Co.

Summary

The Wyoming Supreme Court affirmed judgment for the employer, sustaining the constitutionality of the Wyoming Workmen's Compensation Law (Laws 1915, ch. 124, as amended by Laws 1917, ch. 69) enacted under the 1914 constitutional amendment to Art. X, Sec. 4. The court held that the republican-form-of-government objection is a nonjusticiable political question; that the Seventh Amendment is no barrier because the Act abolishes the common-law right of recovery between employer and employee, leaving nothing for a jury to try; and that compulsory employer contributions to the Industrial Accident Fund irrespective of fault do not deprive employers of property without due process, because common-law negligence rules are subject to legislative change and the fund is a fair and reasonable exercise of the police power. Under the state constitution, the 1914 amendment prevails over inconsistent prior provisions, and classification, schedules, and benefit details are committed to the Legislature.