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The task of a court that is asked to determine whether a particular exercise of congressional power is valid under the Commerce Clause, U.S. Const., art. I, § 8, cl. 2, is relatively narrow. The court must defer to a congressional finding that a regulated activity affects interstate commerce, if there is any rational basis for such a finding. This established, the only remaining question for judicial inquiry is whether the means chosen by Congress must be reasonably adapted to the end permitted by the Constitution. The judicial task is at an end once the court determines that Congress acted rationally in adopting a particular regulatory scheme.
A pre-enforcement challenge to the constitutionality of the Surface Mining Control and Reclamation Act of 1977 (Act) was presented in a Federal District Court action wherein the plaintiffs were an association of coal producers engaged in surface coal mining operations in Virginia, some of its member coal companies, individual landowners, the Commonwealth of Virginia, and a town (hereinafter appellees). The Act is designed to establish a nationwide program to protect society and the environment from the adverse effects of surface coal mining operations. The Secretary of the Interior (Secretary) has primary responsibility for administering the Act by promulgating regulations and enforcing its provisions. A two-stage program for the regulation of surface mining -- an interim phase and a permanent phase -- is established; and environmental protection performance standards are prescribed. Ultimately, a regulatory program is to be adopted for each State, either by approval of a State's proposed permanent program that meets federal minimum standards, or by adoption of a federal program for any State that chooses not to submit a program. Enforcement of the permanent programs rests either with the participating State or with the Secretary as to nonparticipating States. The District Court, although rejecting appellees' Commerce Clause, equal protection, and substantive due process challenges to the Act, held that the Act violates the Tenth Amendment, that various provisions of the Act effect an uncompensated taking of private property in violation of the Just Compensation Clause of the Fifth Amendment, and that some of the Act's enforcement provisions violate procedural due process requirements.
Was the Surface Mining Control and Reclamation Act (30 USCS 1201 et seq.), and specific provisions thereof, violative of the commerce clause, Tenth Amendment, and just compensation and due process clauses of Fifth Amendment?
The Court upheld the Surface Mining and Reclamation Act against plaintiffs' Commerce Clause, U.S. Const., art. I, § 8, cl. 2, claim, because the statute regulated interstate commerce. Coal was a commodity which moved in interstate commerce, and the mining of coal had the potential to impact other natural resources which in turn affected interstate commerce. Plaintiffs' claim that the Act exceeded Congress's commerce power failed to satisfy the first of three requirements necessary to substantiate such a claim. That requirement called for a showing that the challenged statute regulated the states as such. The Act did not regulate states, but regulated the mining operators. The Court found no infringement of the states' U.S. Const. amend X rights. The Act also included provisions allowing for appropriate hearings, precluding a finding of unconstitutionality based on due process violations. Therefore, the Court reversed the lower court's holding that various provisions of the Act were unconstitutional.