Keystone Bituminous Coal Ass'n v. DeBenedictis

United States District Court for the Western District of Pennsylvania · Property

PropertyTakingsPolice PowerContract ClauseEminent DomainMine Subsidencetakingspolice power

Facts

Plaintiffs challenged three provisions of Pennsylvania's Bituminous Mine Subsidence and Land Conservation Act and three DER regulations that restricted underground mining causing subsidence damage, authorized permit revocation for failure to pay for repairs, allowed certain surface owners to purchase supporting coal, expanded protected structures and features, required leaving 50 percent of coal in place for support, and required restoration of damaged surface land. The parties stipulated that in western Pennsylvania many surface owners had previously conveyed the coal and support estates to plaintiffs while retaining the surface estate, so plaintiffs claimed the challenged provisions impaired those contractual arrangements and destroyed their support estate. Defendants, state officials charged with enforcing the statute, argued the law was a valid exercise of the Commonwealth's police power to protect health, safety, and welfare. Plaintiffs did not allege any present injury from enforcement, so the court addressed only the facial constitutional challenge to the enactments.

Issue

Whether the mere enactment of the challenged subsidence-control provisions and regulations violated the Contract Clause, effected an uncompensated taking of plaintiffs' coal or support estates in violation of the Fourteenth Amendment, or, as to the forced-sale provision, constituted an unconstitutional exercise of eminent domain lacking a public purpose.

Rule

When the state is not a party to the contract, a law challenged under the Contract Clause is evaluated by asking whether it substantially impairs a contractual relationship, whether it serves a significant and legitimate public purpose, and whether the adjustment of contractual rights is based on reasonable conditions appropriate to that purpose. For takings, permanent physical occupation or creation of a public easement in private property is a taking, but land-use regulations that restrict use to promote health, safety, morals, or general welfare are valid absent such physical invasion unless they destroy the owner's entire bundle of property rights. In reviewing eminent domain, courts defer to legislative findings of public purpose and do not substitute the landowner's view of public need.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, Ridge Hollow Minerals bought underground limestone rights decades ago under deeds in which surface owners waived any right to lateral support. The state later enacted a statute forbidding extraction beneath hospitals, apartment buildings, and municipal water tunnels to prevent collapse, and the state is not a party to any of the deeds.

If Ridge Hollow argues the statute violates the Contract Clause because it overrides the support waivers, what is the strongest answer?

Explanation. Where the state is not itself a contracting party, the court applies a deferential three-step Contract Clause analysis: substantial impairment, significant and legitimate public purpose, and a reasonable adjustment of contractual rights appropriate to that purpose. A law aimed at preventing collapse under hospitals, residences, and public infrastructure fits the kind of broad health, safety, and welfare purpose the opinion treated as sufficient, and the court deferred to legislative judgment on necessity and reasonableness. (Derived from Keystone Bituminous Coal Ass'n v. DeBenedictis (n.d.).)