Congress passed the Bituminous Coal Conservation Act of 1935, also known as the Guffey-Snyder Coal Act, as an attempt to keep prices and wages in the bituminous coal industry high and to restrict unfair trade practices during the Great Depression. The Act established the National Bituminous Coal Commission (1935-37), which would later be replaced by a new Commission upon enactment of the Bituminous Coal Act of 1937. The Commission was responsible for issuing the Bituminous Coal Code that regulating prices, wages, and hours within the coal industry.
The Act was based on voluntary, incentive-based compliance; those that abided by Act's regulations received tax rebates. In 1936, a stockholder in the Carter Coal Company sued his company to prevent them from paying the noncompliance tax. In the case of Carter v. Carter Oil Company, the Supreme Court of the United States found certain aspects of the 1935 Act to unconstitutional. The Court's finding was based on the Act's regulation of the production process, a violation of private property rights.