Coal River Energy, Case Study Example

The title of this case is Coal River Energy, LLC v. Sally Jewell (13-5119, D.C. Cir. 2014), in which Coal River Energy LLC is the appellant and Sally Jewell, the Secretary of the U.S. Department of the Interior is the appellee. The case was argued on April 4, 2014 in the United States District Court for the District of Columbia and the decision was made on May 13, 2014.

The appellee, Sally Jewell, is a representative of the U.S. Department of the Interior who argued that operators of coal mines must pay a fee for each ton of coal they produce and that this fee is collected at the time of sale or use rather than at the time of mining. This fee is required by the Department to reverse any damage that the mining has caused to the surrounding land. The appellant, Coal River Energy, argued that this regulation is against the Constitution if the coal is sold for export because the Export Clause states that taxes will not be placed on items exported from any state.

This case is going before the Court for adjudication because U.S. Const. Art. I, § 9, cl. 5. states that“No Tax or Duty shall be laid on Articles exported from any state.” However, Congress passed a law in 1977, the Reclamation Act, establishing a fee of “28 cents per ton of coal produced by surface coal mining and 12 cents per ton of coal produced by underground mining.” Coal River Energy believes that the Reclamation Act is unconstitutional because it violates the Export Clause.

Coal River Energy believes that being charged for the coal sold is unconstitutional because taxes cannot be placed on exports from any state. However, a similar case had been reviewed in the past in Consolidation Coal Co. v. United States (528 F.3d 1344, 1348) and it had been determined that the tax required by the Department of the Interior was a fee based on the quantity of coal mined rather than sold, but the sold amount of coal is used as a more precise indicator by the Department to determine its true weight. Therefore, this suit resulted in the favor of the Department of the Interior. As a consequence, the court ruled that this case was untimely because a similar decision regarding the validity of the Reclamation Act had already been reached.

Coal River Energy was not fined damages but will be required to continue paying a fee to the Department of the Interior for its mined coal. The Reclamation Act was deemed constitutional and not in violation of the Export Clause. There is no dissenting opinion in this case. The decision of this case will positively influence the enforcement of environmental health services programs because it will allow the government to maintain environmental landscapes that would be damaged by the mining process. Upholding this fee emphasizes the importance of environmental safety to the Department of the Interior and it demonstrates that in this particular situation, the environment was favored over industry.

The result of this case does not come as a surprise in light of the many laws that regulate mining in a way that promotes environmental stability. For example, Comprehensive Environmental Response, Compensation and Liability Act, Safe Drinking Water Act, and Federal Land Policy and Management Act all work together to ensure that mining companies respect their surroundings during the mining process. Contaminating water sources and harming animal habitats can result in a fine, which encourages companies to be environmentally conscious during their practice.

References

Coal River Energy, LLC v. Sally Jewell, 13-5119 (D.C. Cir. 2014)