Secretary of Labor v. KC Transport, Inc.
Split Score
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Case Summary
Disposition
Vacated
The case concerns whether KC Transport’s truck-maintenance facility, located about a mile from the nearest coal-processing plant and several miles from any extraction site, falls within the Mine Safety and Health Act’s definition of a “mine.” The 12th Circuit held that, after Loper Bright’s rejection of Chevron deference, the best reading of 30 U.S.C. § 802(h)(1)(C) covers facilities necessarily connected to the extraction and preparation of coal even if they are not situated on mine property, thereby vacating the Review Commission’s decision and reinstating MSHA’s safety citations against KC Transport.
Circuit Split Identified
Legal Issue
Whether off-site repair facilities and equipment that are merely connected to extraction operations, but are not located on or immediately adjacent to an extraction site or coal-processing plant, are “mines” within the meaning of 30 U.S.C. § 802(h)(1)(C) and therefore subject to MSHA jurisdiction.
Circuit Positions
Functional approach — a facility or equipment is a ‘mine’ whenever it is necessarily connected with extracting, milling, or preparing coal, regardless of whether it sits on or next to the extraction site.
Geographic approach — only facilities/equipment located at, or immediately adjacent to, a working mine or appurtenant road qualify as ‘mines’.
Conflict Summary
The 6th Circuit construes § 802(h)(1)(C) narrowly, holding that a facility or equipment is a ‘mine’ only if it is located at or physically adjacent to an extraction site or roadway appurtenant thereto. The 12th Circuit in this opinion rejects any strict locational requirement and holds that facilities and equipment are ‘mines’ whenever they are necessarily connected with the work of extracting, milling, or preparing coal, even if they sit miles from the nearest extraction site.