Machipongo Land and Coal Co. v. Commonwealth of Pennsylvania
Pennsylvania Supreme Court
799 A.2d 751 (2002)
- Written by Miller Jozwiak, JD
Facts
Pennsylvania (defendant) had a statute called the Pennsylvania Surface Mining Conservation and Reclamation Act (PSMCRA). The PSMCRA existed pursuant to a federal act that regulated surface mining operations. Under the PSMCRA, Pennsylvania designated certain tracts of land as unsuitable for mining. This resulted in certain property owners (plaintiffs) being unable to remove coal via surface mining. Protracted litigation followed, with the property owners claiming that the unsuitable-for-mining designation constituted a taking. Eventually, the parties went to trial to determine whether the regulation constituted a taking under the Takings Clause. The trial court determined that a taking had occurred. In coming to that conclusion, the trial court had to determine the property that was allegedly taken—in other words, whether the entire property was taken or only certain parts of it. The court concluded that the relevant property was the coal estates in the relevant area, as opposed to the entirety of the property (i.e., all the property rights, including the surface property rights). Pennsylvania appealed.
Rule of Law
Issue
Holding and Reasoning (Newman, J.)
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