Sahara Coal Co. v. Illinois Department of Mines and Minerals

The Sahara Coal Company (Sahara) (plaintiff) submitted an application for mining to the Illinois Department of Mines and Minerals (IDMM) (defendant). The IDMM had implemented various regulations related to strip mining. These regulations included Rule 1104, which was for the reclamation of strip mined land. The rule instigated standards to be followed if the IDMM concluded that the relevant land’s optimum use was for row crop agriculture. The IDMM’s director denied Sahara’s application, citing Rule 1104 and his determination that the land’s optimum use was for row crop agriculture. The administrative record that led to this determination, however, contained little evidence that row crop agriculture was the optimum use of the land. Instead, much of the evidence in the administrative record (such as federal official testimony) indicated that the land would be best used as pasture land, given its eroded topsoil. Indeed, the only evidence that row crop agriculture was the land’s optimum use was the IDMM director’s statement, which was largely conclusory and without any other support. In response to the denial, Sahara sued under Illinois’s Administrative Review Act. The trial court ultimately sided with Sahara, setting aside the IDMM’s denial of the application. But the trial court went further and also ordered an issuance of the permit sought by Sahara. The IDMM appealed.