BARNHART v. SIGMON COAL CO.

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Case Basics
Docket No. 
00-1307
Petitioner 
Barnhart
Respondent 
Sigmon Coal Co.
Advocates
(on behalf of the United Mine Workers Combined Benefit Fund, as amicus curiae)
(Argued the cause for the petitioner)
(Argued the cause for the respondents)
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Facts of the Case 

The Coal Industry Retiree Health Benefit Act of 1992 restructured the system for providing private health care benefits to coal industry retirees by merging two previous benefits plans into the United Mine Workers of America Combined Benefit Fund. The fund is financed by annual premiums assessed against signatory coal operators, or those who signed any agreement requiring contributions to the plans that were merged into the Fund. If the signatory is no longer in business, the Act assigns liability for beneficiaries to a defined group of "related persons" based on the Commissioner of Social Security assignments. Shortly after Jericol Mining Co. was formed in 1973 as Irdell Mining, Inc., Irdell purchased the coal mining operating assets of Shackleford Coal Co., which was a signatory to a coal wage agreement while it was in business. Between 1993 and 1997, the Commissioner assigned responsibility for 86 retired miners to Jericol, determining that as a successor in interest to Shackleford, Jericol qualified as a related person. All of these retirees had worked for Shackleford, but none of them had actually worked for Jericol. Jericol filed suit against the Commissioner. The District Court granted Jericol summary judgment, concluding that the Act's classification regime does not provide for the liability of successors of defunct signatory operators. In affirming, the Court of Appeals concluded that Jericol was not a related person to Shackleford and thus could not be held responsible for Shackleford's miners.

Question 

Does the Coal Industry Retiree Health Benefit Act of 1992 permit the Commissioner of Social Security to assign retired miners to the successors in interest of out-of-business signatory operators?

Conclusion 
Decision: 6 votes for Sigmon Coal Co., 3 vote(s) against
Legal provision: 26 U.S.C. 9701

No. In a 6-3 opinion delivered by Justice Clarence Thomas, the Court held that the Act did not permit the Commissioner to assign retired miners to the successors in interest of out-of-business signatory operators, since the companies were not related to such operators under the Act's statutory definitions. Justice Thomas reasoned that, because the Act is explicit as to who may be assigned liability for beneficiaries and neither the related persons provision nor any other provision states that successors in interest to these signatory operators may be assigned liability, the Act's plain language necessarily precluded the Commissioner from assigning the disputed miners to Jericol. Justice John Paul Stevens wrote a dissenting opinion, joined by Justices Sandra Day O'Connor and Stephen G. Breyer.

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BARNHART v. SIGMON COAL CO.. The Oyez Project at IIT Chicago-Kent College of Law. 24 October 2014. <http://www.oyez.org/cases/2000-2009/2001/2001_00_1307>.
BARNHART v. SIGMON COAL CO., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2001/2001_00_1307 (last visited October 24, 2014).
"BARNHART v. SIGMON COAL CO.," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 24, 2014, http://www.oyez.org/cases/2000-2009/2001/2001_00_1307.