Keystone Bituminous Coal Association. v. DeBenedictis (1986)
- Docket
- 85-1092
- Decided
- 1986-01-01
Summary
Question: 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? Conclusion: 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.