The dispute centers on whether the Mine Act’s jurisdictional definition of a “mine” extends to facilities located away from active extraction sites. KC Transport, Inc. operates a maintenance shop in Emmett, West Virginia, approximately one mile from a client’s coal processing plant and several miles from active mines.
MSHA inspectors cited KC Transport after observing two haul trucks undergoing maintenance at the facility. The trucks were raised and unblocked, with one person standing underneath a vehicle, conditions the agency determined violated federal safety standards.
KC Transport contested the citations, arguing that MSHA lacked jurisdiction because the facility was not located on land where mineral extraction occurs or on roads appurtenant to such land.
An administrative law judge ruled in favor of the agency, determining that the facility and the trucks were “used in” mining activity and thus fell within the statutory definition of a mine.
The Federal Mine Safety and Health Review Commission reversed, holding that no facility or truck used in mining is a “mine” unless it is located at an extraction site or on appurtenant roads.
The Secretary of Labor petitioned the D.C. Circuit for review. In a 2023 decision, the court had vacated the Commission’s ruling, finding the term “mine” ambiguous and remanding for the Secretary to provide a reasonable interpretation.
The Supreme Court subsequently granted certiorari, vacated the judgment, and remanded the case for reconsideration in light of its decision in Loper Bright Enterprises v. Raimondo, which overruled Chevron deference.
On remand, the D.C. Circuit exercised independent judgment, applying traditional tools of statutory construction to resolve the ambiguity without deferring to the agency.
The court concluded that the facility and the trucks were “used in” mining-related activity, bringing them within the Mine Act’s definition of a mine.
The opinion was filed by Circuit Judge Wilkins, with a concurrence by Judge Pan and a dissent by Judge Walker.