United States v. Stearns Coal and Lumber Co.
United States Court of Appeals for the Sixth Circuit
816 F.2d 279 (1987)

- Written by Miller Jozwiak, JD
Facts
The Stearns Coal and Lumber Company (Stearns) (plaintiff) conveyed a large tract of land to the United States (defendant) to be added to a national forest. The deed reserved to Stearns certain mineral rights. The terms of the deed did not expressly address the subject of strip mining (although it did expressly exclude from its terms hydraulic mining). The deed also stated that Stearns could make improvements on the land to access the property so long as Stearns removed any structures or buildings after completing the mining. The deed was not a broad form deed, as was common in Kentucky around the time that the deed was entered. Broad form deeds contained broad language that Kentucky courts later concluded allowed for any feasible type of mining, even if that type of mining was not in existence when the parties entered the deed. Stearns and the United States later disputed whether the deed authorized strip mining. In United States v. Stearns Co., the district court sided with the United States, concluding that the deed did not authorize strip mining. Stearns appealed.
Rule of Law
Issue
Holding and Reasoning (Engel, J.)
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