Hodel v. Indiana
Annotate this Case
452 U.S. 314 (1981)
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U.S. Supreme Court
Hodel v. Indiana, 452 U.S. 314 (1981)
Hodel v. Indiana
Argued February 23, 1981
Decided June 15, 1981
452 U.S. 314
This appeal involves a constitutional challenge to the so-called "prime farmland" provisions and certain general provisions of the Surface Mining Control and Reclamation Act of 1977 (Act). The prime farmland provisions establish special requirements for surface coal mining operations conducted on land that both qualifies as prime farmland and has historically been used as cropland. These provisions include § 510(d)(1), which requires an applicant for a permit for mining on prime farmland to show that he has the capacity to restore the land, within a reasonable time after the completion of mining, to the productivity level of prime farmland in the surrounding area; § 519(c)(2), which conditions release of a mine operator's bond on the completion of such restoration; and § 508(a)(2), which directs mine operators to include information about the premining productivity of the land in the reclamation plans filed as part of permit applications. The general provisions in question include § 515(b)(3), which requires restoration of mined land to its approximate original contour; § 515(b)(5), which requires surface mine operators to remove topsoil separately and preserve it for use during reclamation; § 508, which requires applicants for surface mining permits to submit reclamation plans; §§ 522(a), (c), and (d), which require States wishing to regulate surface mining to establish an administrative procedure for determining whether particular lands are unsuitable for surface mining; § 522(e), which proscribes mining within a specified distance of roads, cemeteries, public buildings, schools, churches, public parks, or dwellings; and the Act's procedures for collecting civil penalties from violators of the Act, including a requirement that a contested penalty be paid into an escrow account pending review. Appellees (the State of Indiana and several of its officials, the Indiana Coal Association, several coal mine operators, and others) filed suits in Federal District Court, alleging that the provisions in question contravene the Commerce Clause, the equal protection and due process guarantees of the Due Process Clause of the Fifth Amendment, the Tenth Amendment, and the Just Compensation Clause of the Fifth Amendment. The District Court sustained each of the constitutional
challenges and permanently enjoined enforcement of the challenged provisions.
Held: The Act is not vulnerable to appellees' preenforcement constitutional challenge. Pp. 452 U. S. 321-336.
(a) The provisions in question do not violate the Commerce Clause. The Act was adopted to ensure that production of coal for interstate commerce would not be at the expense of agriculture, the environment, or public health and safety, and to protect mine operators in States adhering to high performance and reclamation standards from disadvantageous competition with operators in States with less rigorous regulatory programs. The challenged provisions advance these legitimate goals, and Congress acted reasonably in adopting the regulatory scheme contained in the Act. Pp. 452 U. S. 321-329.
(b) Nor do the challenged provisions contravene the Tenth Amendment. Such provisions regulate only the activities of surface mine operators who are private individuals and businesses, and do not directly regulate the States as States. P. 452 U. S. 330.
(c) The prime farmland and "approximate original contour" provisions do not violate the equal protection and due process guarantees of the Fifth Amendment. Congress acted rationally in making no allowances for variances from the prime farmland requirements and in allowing variances from the approximate original contour only for steep slope and mountaintop operations. The fact that a particular State has more mining operations under prime farmland and fewer steep slope or mountaintop operations than another State does not establish impermissible discrimination Under the Fifth Amendment's Due Process Clause. And, by invalidating the prime farmland and "approximate original contour" provisions under the rubric of "substantive due process," the District Court essentially acted as a superlegislature, and accordingly exceeded its proper role. Pp. 452 U. S. 331-333.
(d) Sections 510(d)(1), 519(c)(2), 508(a)(2), and 522(a), (c),( d), and (e) do not take private property without just compensation in violation of the Fifth Amendment. Appellees' taking claims do not focus on any particular properties to which the challenged provisions have been applied. Similarly, the District Court's ruling did not pertain to the taking of a particular piece of property or the denial of a mining permit for specific farmland operations proposed by appellees. The "mere enactment" of the Act did not effect an unconstitutional taking of private property. The prime farmland provisions do not prohibit surface mining but merely regulate the conditions under which such mining may be conducted. Pp. 452 U. S. 333-335.
(e) Appellees' challenge to the civil penalty provisions of the Act as
depriving mine operators of their right to due process is premature, where appellees have not shown that they were ever assessed civil penalties, much less that the statutory prepayment requirement was ever applied to them or caused them any injury. Pp. 452 U. S. 335-336.
501 F.Supp. 452, reversed and remanded.
MARSHALL, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, STEWART, WHITE, BLACKMUN, POWELL, and STEVENS, JJ., joined. BURGER, C.J., filed a concurring statement, ante p. 452 U. S. 305. REHNQUIST, J., filed an opinion concurring in the judgment, ante p. 452 U. S. 307.