The court also resolved a significant Article III justiciability dispute, ruling that the Secretary of Labor’s petition for review of the Federal Mine Safety and Health Review Commission’s decision did not present a non-justiciable intra-Executive branch conflict.
The dispute arose after an MSHA inspector visited KC Transport’s maintenance facility in Emmett, West Virginia, to check on trucks previously cited for safety violations. The inspector observed two haul trucks undergoing maintenance while unblocked from motion, with one truck raised and a worker standing underneath it.
The inspector cited KC Transport for violating 30 C.F.R. § 77.404(c), which requires machinery to be blocked against motion during repairs. The administrative law judge upheld the citations, but the Federal Mine Safety and Health Review Commission reversed, holding that the facility was not a "mine" because it was not located at an extraction site or on roads appurtenant to one.
The Secretary of Labor petitioned the D.C. Circuit for review. The court first addressed KC Transport’s argument that the proceeding was an unconstitutionally intra-Executive dispute because the Secretary was suing the Commission.
The court rejected this argument, noting that the Commission had declined to participate as an active litigant and stood on its prior decision. The court held that the Commission’s role as a nominal respondent did not create a case or controversy sufficient to implicate Article III justiciability concerns.
The court further held that striking the Commission as a respondent was appropriate to obviate any constitutional issues, relying on precedent that purely adjudicatory bodies are not proper parties in judicial review of their own decisions.
On the merits, the court reviewed the definition of "mine" under 30 U.S.C. § 802(h)(1) de novo, following the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo which overruled Chevron deference.
The statute defines a mine to include facilities "used in, or to be used in, or resulting from" mining activity. The court concluded that the facility was necessarily connected with the use and operation of extracting and preparing coal.
The facility was located less than 1,000 feet from a private haul road and about a mile from a coal processing plant. Sixty percent of the services provided at the facility supported Ramaco Resources, a coal mine operator, and the cited trucks were actively used to haul coal between the mine and the preparation plant.
The court held that such a facility is a "mine" under subsection (C) of the statute, regardless of whether it is located on the extraction site itself. The court vacated the Commission’s decision and affirmed the Secretary’s citations.