Barnhart v. Sigmon Coal Co. - 534 U.S. 438, 122 S. Ct. 941 (2002)

Rule:

In all statutory construction cases, the court begins with the language of the statute. The first step is to determine whether the language at issue has a plain and unambiguous meaning with regard to the particular dispute in the case. The inquiry ceases if the statutory language is unambiguous and the statutory scheme is coherent and consistent. 

Facts:

The Coal Industry Retiree Health Benefit Act of 1992 (Coal Act or Act) restructured the system for providing private health care benefits to coal industry retirees. The Act merged the 1950 and 1974 Benefit Plans -- which were created pursuant to collective-bargaining agreements between the United Mine Workers of America (UMWA) and coal operators -- into a new multiemployer plan called the UMWA Combined Benefit Fund (Combined Fund). See 26 U.S.C. § 9702(a). That fund is financed by annual premiums assessed against "signatory coal operators," i.e., those who signed any agreement requiring contributions to the 1950 or 1974 Benefits Plans. Where the signatory is no longer in business, the Act assigns liability for beneficiaries to a defined group of "related persons." The Act charges the Commissioner of Social Security with assigning each eligible beneficiary to a signatory operator or its related persons, § 9706(a); identifies specific categories of signatory operators (and their related persons) and requires the Commissioner to assign beneficiaries among these categories in a particular order, ibid.; and ensures that if a beneficiary remains unassigned because no existing company falls within the categories, benefits will be financed by the Combined Fund, see §§ 9704(a), (d), 9705(b). Shortly after respondent Jericol Mining Co. (Jericol) was formed in 1973 as Irdell Mining, Inc., Irdell and another company purchased the coal mining operating assets of Shackleford Coal Co., which was a signatory to a coal wage agreement while it was in business. Among other things, they assumed responsibility for Shackleford's collective-bargaining agreement with the UMWA. There was no common ownership between Irdell and Shackleford. Irdell subsequently changed its name, operating as the Shackleford Coal Co. until 1977, when it again changed its name to Jericol. Between 1993 and 1997, the Commissioner assigned premium responsibility for 86 retired miners to Jericol under § 9706(a)(3), determining that as a "successor" or "successor in interest" to the original Shackleford, Jericol qualified as a "related person" to Shackleford. All of these retirees had worked for Shackleford, but none of them had actually worked for Jericol. Jericol and respondent Sigmon Coal Company, Inc., a person related to Jericol under § 9701(c)(2), filed suit against the Commissioner. The District Court granted them summary judgment, concluding that the Act's classification regime does not provide for the liability of successors of defunct signatory operators. In affirming, the Fourth Circuit concluded that the Act was clear and unambiguous and that the court was bound to read it exactly as it was written, and held, inter alia, that Jericol was not a "related person" to Shackleford and thus could not be held responsible for Shackleford's miners.

Issue:

Did the Coal Act permit the Commissioner to assign retired miners to the successors in interest of out-of-business signatory operators?

Answer:

No.

Conclusion:

The United States Supreme Court held that the Coal Act unambiguously permitted assignment of the retired miners only to persons related to the signatory operator, and the companies were thus not subject to the assignments since they were not such related persons. The companies' status as successors in interest to the signatory was not within the statutory definition of "related person," and any asserted intention of Congress to avoid a lack of health benefits for the retirees was insufficient to overcome the plain language of the statute. Further, the Coal Act did not delegate authority to the commissioner to develop new guidelines or to assign liability in a manner inconsistent with the statute.