Keystone Bituminous Coal Association v. DeBenedictis
"Keystone Bituminous Coal Association v. DeBenedictis" is a significant legal case that centers on the balance between state regulation and property rights in the context of coal mining in Pennsylvania. In 1966, the Pennsylvania legislature enacted a law aimed at preventing subsidence damage to public buildings, dwellings, and cemeteries caused by coal mining activities. The Keystone Bituminous Coal Association challenged this law, arguing that it effectively restricted their ability to mine coal, resulting in a claim for compensation under the Takings Clause of the Fifth Amendment. The Association also contended that the law interfered with existing contracts that waived liability for surface damage.
In a closely contested 5-4 decision, the U.S. Supreme Court, led by Justice John Paul Stevens, upheld the state law, asserting that states have the right to exercise police powers for the public good. The Court concluded that the law did not constitute a taking since it only limited access to a small percentage of coal reserves. Additionally, the ruling clarified that impairments of contract obligations could be deemed reasonable when connected to significant public interests, suggesting a nuanced view of contractual rights in the context of state regulations. This case illustrates the complexities of property rights, environmental protection, and the regulation of natural resources, reflecting a broader discourse on government intervention and economic interests.
Keystone Bituminous Coal Association v. DeBenedictis
Date: March 9, 1987
Citation: 480 U.S. 470
Issues: Takings clause; contracts clause
Significance: The Supreme Court held that a Pennsylvania law prohibiting underground mining that causes damage to surface structures does not violate either the takings clause or the contracts clause.
In 1966 the Pennsylvania legislature enacted a law prohibiting coal mining that caused subsidence damage to preexisting public buildings, dwellings, and cemeteries. Based on Pennsylvania Coal Co. v. Mahon (1922), the Keystone Bituminous Coal Association argued that it should be paid compensation for its inability to mine coal in certain places. The company also alleged that the law prevented the enforcement of its existing contracts that waived liability for surface damage.
Speaking for a 5-4 majority, Justice John Paul Stevens reasoned that a state could exercise its police power to protect the public’s safety and welfare and that no Fifth Amendment taking occurs when landowners are not deprived of all economic use of their property. Observing that the statute deprived the company of less than 2 percent of its coal, Stevens found that Court precedents did not allow the company to divide property parcels into component parts when deciding whether the government was required to pay compensation. In regard to the contracts clause challenge, Stevens found that established precedents allowed contractual impairments judged reasonable and necessary for achieving important public purposes. “It is well-settled,” he wrote, “that the prohibition against impairing the obligation of contracts is not to be read literally.”