## Facts

- Collins owned and occupied a home near an iron works operated by Wayne Iron Works.
- The iron works sat on land between Collins’s residence and a railroad.
- Wayne Iron Works used heavy machinery (including drills, power hammers, chippers, and riveting machines), sometimes operated outdoors or with building windows open.
- The noise and manner of operation, including work continuing into the evening, allegedly made nearby homes uncomfortable and interfered with residential use and enjoyment.
- Collins brought an equity action seeking an injunction to abate the alleged private nuisance.

## Issues

1. Whether the iron works’ noise-producing operations, as conducted, constituted a private nuisance interfering with a neighboring homeowner’s use and enjoyment of property.
2. If a nuisance existed, whether the injunction must be stated in definite, precise terms and whether equity may impose partial, condition-based limits rather than ordering total cessation of operations.

## Decision

- The Supreme Court of Pennsylvania modified the trial court’s decree rather than eliminating injunctive relief.
- The court imposed specific operational restrictions:
  - Wayne Iron Works was enjoined from operating noisy tools between 7:00 p.m. and 7:00 a.m.
  - At other times, it was restrained from operating such tools unless the work occurred inside buildings with windows closed.
- The business could continue if it complied with these conditions.

## Legal Principles

- A lawful industrial enterprise may constitute a private nuisance if operated in a manner that unreasonably interferes with neighboring owners’ residential use and enjoyment of their property.
- The character of the surrounding area (including proximity to railroads or nonresidential parcels) does not categorically bar nuisance relief when the interference is unreasonable.
- Equity may grant qualified or partial injunctions that abate the nuisance while permitting continued lawful operation under reasonable time-and-manner restrictions.
- Injunctions should be definite, clear, and precise, stating restrained acts in objective terms so the defendant need not guess at compliance.

## Conclusion

The court recognized actionable interference from industrial noise but required that equitable relief be narrowly stated and administrable, modifying a broad nuisance decree into specific, time-limited and condition-based restrictions rather than shutting down the iron works.


Collins v. Wayne Iron Works, 227 Pa. 326 (1910)