Hodel v. Indiana

Congress enacted the Surface Mining Control and Reclamation Act of 1977 (the act) in order to protect air and water pollution as well as preserve the productive capacity of mined lands and protect the public from health and safety hazards associated with surface coal mining. The act contained sections that established special requirements for surface-mining operations conducted on land that qualified as prime farmland. These provisions were known as the prime-farmland provisions. The prime-farmland provisions required that surface coal permits would only be issued on prime farmland if the mine operator could demonstrate its technological capability to restore the mined area to the equivalent levels of yield as the surrounding nonmined prime farmland. Operators also had to show they could meet soil-reconstruction standards of prime farmland. Hodel (plaintiff) brought suit in district court against Indiana (defendant), challenging the constitutionality of the provisions. The district court ruled that the provisions of the act were unconstitutional because they went beyond congressional power to regulate interstate commerce and violated the Commerce Clause. The district court found that surface coal mining had no substantial and adverse effect on interstate commerce and permanently enjoined the enforcement of the prime-farmland provisions.