''Barnhart v. Peabody Coal Co.'', 537 U.S. 149 (2003), was a
Supreme Court of the United States
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
case.
[. ] The case was to determine if a law instructing a government agent "shall" perform an action by a given date was intended as a 'spur to action' or a limit on whether the agent could act after the date. In this case the court held the agent could still act even after the date.
Background
The Coal Industry Retiree Health Benefit Act of 1992 stated that "The
Commissioner of Social Security shall, before October 1, 1993, assign each
coal industry
Coal is a combustible black or brownish-black sedimentary rock, formed as rock strata called coal seams. Coal is mostly carbon with variable amounts of other elements, chiefly hydrogen, sulfur, oxygen, and nitrogen.
Coal is formed when de ...
retiree eligible for benefits under the Act to an extant operating company responsible for funding the beneficiary's benefits." The assignment to an operator, like
Peabody Coal, binds the operator to pay an annual premium to the
United Mine Workers of America
The United Mine Workers of America (UMW or UMWA) is a North American Labor history of the United States, labor union best known for representing coal miners. Today, the Union also represents health care workers, truck drivers, manufacturing worke ...
Combined Benefit Fund, which administers the benefits.
Legal question
The question before the court was whether or not eligible retirees could be assigned to an operator after the October 1st date specified in the Act. If the retirees could not be assigned to an operator, the company they would have been assigned to would be free of obligation. The mining companies argued the date in the Act limited the commissioner's ability to assign eligible retirees to an operator. The commissioner argued the Act had been set to spur timely completion and that assignments could be made after that date.
Court's decision
The court held for the commissioner. Citing precedent,
[.] the court ruled that the assignments could be made after the date and interpreted that "Congress had intended the work to be done by that date not that it could not be done after that date".
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See also
* List of United States Supreme Court cases, volume 537
This is a list of all the United States Supreme Court cases from volume 537 of the ''United States Reports
The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, ...
* List of United States Supreme Court cases
* ''United States v. Navajo Nation'' (2009): also involved Peabody Coal Co.
References
External links
*
United States Supreme Court cases
2003 in United States case law
United States Supreme Court cases of the Rehnquist Court
United Mine Workers of America litigation
Pension regulation
Coal mining in the United States
Peabody Energy
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