Eastern Enterprises v. Apfel

Between 1949 and 1971, the federal government brokered coal-industry agreements that required coal companies to contribute to health-benefit funds for miners and their dependents. The funds did not set benefit levels or guarantee lifetime healthcare. After the agreements were expanded in 1974 to provide benefits to retirees, the funds experienced financial trouble. In 1992, Congress enacted the Coal Industry Retiree Health Benefit Act (Coal Act) to address funding for retired miners’ healthcare. The Coal Act established a Combined Benefit Fund financed by annual premium payments from the same companies that previously contributed to the government-arranged health-benefit funds. Coal-mine operator Eastern Enterprises (plaintiff) contributed to the original health-benefit funds but stopped actively participating in the coal industry in 1965. After the Coal Act was enacted, Social Security Commissioner Kenneth Apfel (defendant) informed Eastern that it owed premiums to the Combined Benefit Fund for over 1,000 retired miners who worked for Eastern before 1966. Eastern’s total estimated premium payments could equal $100 million. Eastern sued Apfel, alleging violations of the Due Process and Takings Clauses of the United States Constitution. The district court granted summary judgment for Apfel, and the appellate court affirmed. The United States Supreme Court granted certiorari.