FLASHBACK: Murder In The Coalfields
Today we look at State v. Michael, 74 W.Va. 613, 82 S.E. 611 (1914)
In the early 1900s, violence swept through the coalfields of southern West Virginia as coal miners organized a strike for greater pay and protection. Coal operators hired the Baldwin-Felts Detective Agency in an attempt to break the strike. By the fall of 1912, the situation had become so volatile that Governor Glasscock issued a proclamation imposing martial law.
In late 1912, national guardsmen began replacing the Baldwin-Felts guards. The defendant, L. J. Michael, was a guardsman from Fairmont who was hired to protect property belonging to the coal mine. On January 15, 2013, the defendant was riding a train to Eskdale, a small mining town. When he arrived at Eskdale, a crowd had gathered at the train station yelling threats. According to the defendant, two men in the crowd were acting suspiciously, one of whom was the victim, John Miller. The defendant was hit by a stone thrown by one of the two men. Fearing for his life, the defendant pulled out a handgun and fired. The victim was shot in the head and killed.
The defendant was charged with second degree murder. The case was tried, and a Greenbrier County jury returned a guilty verdict. The defendant was sentenced to a six year term of confinement. The defendant then appealed, claiming that the jury instructions were erroneous.
The Supreme Court agreed, finding that the instructions limited the jury to only two options--second degree murder or acquittal. Thus, the jury was prevented from considering and returning a verdict for manslaughter. Because the instruction was, in effect, binding on the jury, a new trial was warranted. But the opinion didn’t stop there. The Supreme Court concluded, on a 4-1 vote, that the defendant did not act with malice and, therefore, could not have been convicted of murder. The lone dissenter, Justice Robinson, criticized his brethren for going too far: “Particularly out of place, in my humble judgment, is the expression of opinion that the homicide was committed without malice. Surely that is a matter which should have been left to the determination of a jury.”
Especially in times of social upheaval, it is difficult for the Supreme Court to stand above the fray. From the turn of the century until the early 1920s, all five of the Supreme Court seats were held by business-minded Republicans. In the coalfields, however, sympathy for the coal miners and their plight ran deep. In this case, neither the conviction nor the reversal is really surprising. In all likelihood, the defendant was convicted again when his case was retried--this time for manslaughter. But, above all, this case reminds us that the work of the Supreme Court always grows out of real people and real situations, and its opinions have a real impact on our lives.
