Law School Case Brief
Hodel v. Indiana - 452 U.S. 314, 101 S. Ct. 2376 (1981)
Social and economic legislation carries with it a presumption of rationality that can only be overcome by a clear showing of arbitrariness and irrationality.
The State of Indiana and several of its officials and the Indiana Coal Association and several coal mine operators brought suits against the Secretary of the Interior in the United States District Court for the Southern District of Indiana, alleging that the Surface Mining Control and Reclamation Act of 1977 (30 USCS 1201 et seq.) contravened the commerce clause of the United States Constitution (Art I, 8, cl 3), 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 basic structure of the Surface Mining Act is described in Hodel v. Virginia Surface Mining & Reclamation Assn., Inc. Several of the challenged sections of the Act are known collectively as the "prime farmland" provisions. These sections establish special requirements for surface mining operations conducted on land that both qualifies as prime farmland under a definition promulgated by the Secretary of Agriculture and has historically been used as cropland within the meaning of the regulations of the Secretary of the Interior (Secretary) implementing the Surface Mining Act. § 701 (20), 30 U. S. C. § 1291 (20) (1976 ed., Supp. III). The district court found certain sections of the Act unconstitutional and enjoined enforcement of those provisions; the Secretary appealed.
Did the challenged sections of the Surface Mining Control and Reclamation Act of 1977 violate the Tenth Amendment on the ground that it interfered with the State's land use regulations?
The Supreme Court of the United States found that the pertinent inquiry was whether Congress could rationally conclude that the regulated activity affected interstate commerce and held that the rational basis test was satisfied because its inquiry was directed at how the prime farmland acreage might be affected by surface coal mining. The Court found that the sections challenged by the State were reasonably related to the legitimate goal of protecting interstate commerce from the adverse effects of surface mining. The Court held that the district court erred when it found that the challenged sections violated the Tenth Amendment because the sections only regulated the activities of surface mine operators who were private individuals and businesses and did not interfere with the State's land use regulations. The court reversed the judgment of the district court, which found certain sections of the Surface Mining Act unconstitutional and remanded with instructions that the district court dissolves the injunction entered against the Secretary.
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