Annaco, Inc. v. Hodel

675 F. Supp. 1052 (1987)

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Annaco, Inc. v. Hodel

United States District Court for the Eastern District of Kentucky
675 F. Supp. 1052 (1987)

Facts

The Surface Mining Control and Reclamation Act (SMCRA) regulated strip mining in the United States. However, the SMCRA generally exempted strip mines of two acres or less. But if separate small tracts of land met the SMCRA’s relatedness standard, that exemption would be lost, and the small mines would be subject to the law. A mining site met the relatedness standard if it was two acres or less and was physically and economically related to another small mining site. The SMCRA also authorized states to enact their own regulatory schemes that were equally or more stringent than the SMCRA. Kentucky did so and sought to regulate strip mining at its borders. The federal government (defendant) inspected the mines of Annaco, Inc. (plaintiff) and found them to be in violation of the relatedness provision. The federal government notified the Kentucky government of the issue. Eventually, Kentucky reached a settlement with Annaco that did not require Annaco to reclaim the land. But the federal government again inspected the land and concluded that the violation persisted. Annaco then petitioned an administrative-law judge (ALJ) for temporary relief from the federal government’s order, which the ALJ denied. Annaco appealed, claiming that the federal government did not have jurisdiction because Kentucky had enacted a more stringent system for implementing the SMCRA.

Rule of Law

Issue

Holding and Reasoning (Siler, C.J.)

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