By passing the the Bituminous Mine Subsidence and Land Conservation Act (Act), the Pennsylvania Legislature empowered the Pennsylvania Department of Environmental Resources (DER) to regulate underground coal mining that damaged structures on the surface. When implementing the Act, DER prevented coal miners from removing more than 50% of coal from mines located beneath buildings. Historically, coal miners acquired rights to "mining estates" separate from the property owned on the above "surface estates." The Keystone Bituminous Coal Association, a group of miners, complained that the Act created a "support estate" that effectively took away its property without compensation. Keystone relied on the Supreme Court's decision in Pennsylvania Coal Co. v. Mahon to allege that this state action violated the Contract Clause and the Takings Clause found in the Fifth and Fourteenth Amendments. The District Court rejected both allegations and the United States Court of Appeals for the Third Circuit affirmed the decision.
Does a state violate the Takings Clause by forcing coal mining companies to keep certain amounts of coal in underground mines in order to support structures on the surface?
Does this restriction violate the Contract Clause by canceling agreements miners have made to secure their rights to underground coal?
No and No. Justice John Paul Stevens delivered the opinion of a 5-4 court. Like in Pennsylvania Coal, the Court's decision depended upon the "particular facts" of the mining regulation in question. Unlike in Pennsylvania Coal, the Court found a valid public purpose behind the present Act and determined the Act would not make it impossible for the miners to profitably conduct business. Therefore the decision in Pennsylvania Coal did not apply. To refute alleged Takings Clause violations, the Court established that "the support estate has value only insofar as it is used to exploit another estate." Then the Court conducted a factual review of the effects of the new regulation. It concluded that "[b]ecause petitioners retain the right to mine virtually all the coal in their mineral estates, the burden the Act places on the support estate does not constitute a taking." The Court also dismissed alleged Contract Clause violations because the state acquired no property for itself, but rather used its police power to implement regulation which served valid public interests.
Decisions
Decision: 5 votes for Debenedictis, 4 vote(s) against Legal provision: Takings Clause
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Full Opinion by Justice John Paul Stevens
