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Haydo v. Amerikohl Mining, Inc.

830 F.2d 494 (1987)

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Haydo v. Amerikohl Mining, Inc.

United States Court of Appeals for the Third Circuit

830 F.2d 494 (1987)

Facts

Donald and Patricia Haydo (plaintiffs) alleged that Amerikohl Mining, Inc. (Amerikohl) (defendant) adversely affected the Haydos’ water supply through exploratory drilling that was part of Amerikohl’s coal-exploration program. The Haydos filed a complaint in district court seeking damages for the loss of a water well and argued that Amerikohl violated the environmental-protection standards prescribed by § 515 of the Surface Mining Control and Reclamation Act (SMCRA). The Haydos also alleged that Amerikohl violated state regulations because the Commonwealth of Pennsylvania administered the SMCRA under a program approved by the secretary of the Interior and promulgated regulations pursuant to § 515 of the SMCRA concerning the reclamation of the prevailing hydrologic balance. The Haydos asserted that the district court had subject-matter jurisdiction to hear the claim under § 520 of the SMRCA. Section 520 conferred jurisdiction on federal district courts to hear citizen suits against any person who is alleged to be in violation of any rule or regulation issued pursuant to the SMCRA. The Haydos urged the court to interpret § 520 to include state regulations when the regulations are required by the SMCRA. Amerikohl argued that the district court lacked subject-matter jurisdiction because the Haydos only alleged violations of SMCRA itself and violations of the state regulatory plan and § 520 conferred federal jurisdiction over alleged violations of federal regulations. Under § 503 of the SMCRA, states were permitted to submit a regulatory plan for approval if the state wished to assume exclusive jurisdiction over the regulation of surface coal mining and reclamation operations. Amerikohl claimed that § 503 provided Pennsylvania courts with exclusive jurisdiction of the alleged violations of the state statute and regulations because Pennsylvania had an approved regulatory plan. The district court agreed with Amerikohl and found the court lacked subject-matter jurisdiction. The complaint was dismissed, and the Haydos appealed.

Rule of Law

Issue

Holding and Reasoning (Mansmann, J.)

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