Barnhart v. Peabody Coal Co. | |
---|---|
Argued October 8, 2002 Decided January 15, 2003 | |
Full case name | Jo Anne B. Barnhart, Commissioner of Social Security, Petitioner v. Peabody Coal Company, et al.; Jo Anne B. Barnhart, Commissioner of Social Security, Petitioner v. Bellaire Corporation, et al.; Michael H. Holland, et al., Petitioners v. Bellaire Corporation, et al. |
Citations | 537 U.S. 149 ( more ) 123 S. Ct. 748; 154 L. Ed. 2d 653; 2003 U.S. LEXIS 752; 71 U.S.L.W. 4041; 29 Employee Benefits Cas. (BNA) 2089; 2003 Cal. Daily Op. Service 419; 2003 Daily Journal DAR 501; 16 Fla. L. Weekly Fed. S 35 |
Case history | |
Prior | On writs of certiorari to the United States Court of Appeals for the Sixth Circuit. Peabody Coal Co. v. Massanari, 14 F. App'x 393, 2001 U.S. App. LEXIS 14471 (2001). Bellaire Corp. v. Massanari, 14 Fed. Appx. 424, 2001 U.S. App. LEXIS 14784 (2001) |
Court membership | |
| |
Case opinions | |
Majority | Souter, joined by Rehnquist, Stevens, Kennedy, Ginsburg, Breyer |
Dissent | Scalia, joined by O'Connor, Thomas |
Dissent | Thomas |
Laws applied | |
The Coal Industry Retiree Health Benefit Act of 1992 (26 U.S.C. § 9706(a)) |
Barnhart v. Peabody Coal Co., 537 U.S. 149 (2003), was a Supreme Court of the United States case. [1] 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.
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 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 Combined Benefit Fund, which administers the benefits.
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.
The court held for the commissioner. Citing precedent, [2] 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". [1]
In the United States, Social Security is the commonly used term for the federal Old-Age, Survivors, and Disability Insurance (OASDI) program and is administered by the Social Security Administration (SSA). The original Social Security Act was enacted in 1935, and the current version of the Act, as amended, encompasses several social welfare and social insurance programs.
The United States Court of Appeals for the Second Circuit is one of the thirteen United States Courts of Appeals. Its territory comprises the states of Connecticut, New York and Vermont. The court has appellate jurisdiction over the district courts in the following districts:
The United States Court of Appeals for the Federal Circuit is a United States court of appeals that has special appellate jurisdiction over certain types of specialized cases in the U.S. federal court system. It has exclusive appellate jurisdiction over all U.S. federal cases involving patents, trademarks, government contracts, veterans' benefits, public safety officers' benefits, federal employees' benefits, and various other categories. Unlike other federal courts, the Federal Circuit has no jurisdiction over cases involving criminal, bankruptcy, immigration, or U.S. state law.
Senior status is a form of semi-retirement for United States federal judges. To qualify, a judge in the federal court system must be at least 65 years old, and the sum of the judge's age and years of service as a federal judge must be at least 80 years. As long as senior judges carry at least a 25 percent caseload or meet other criteria for activity, they remain entitled to maintain a staffed office and chambers, including a secretary and their normal complement of law clerks, and they continue to receive annual cost-of-living increases. Senior judges vacate their seats on the bench, and the president may appoint new full-time judges to fill those seats.
Tricare is a health care program of the United States Department of Defense Military Health System. Tricare provides civilian health benefits for U.S Armed Forces military personnel, military retirees, and their dependents, including some members of the Reserve Component. Tricare is the civilian care component of the Military Health System, although historically it also included health care delivered in military medical treatment facilities. Tricare functions similar to a single-payer healthcare system.
The United States Postal Regulatory Commission, formerly called the Postal Rate Commission, is an independent regulatory agency created by the Postal Reorganization Act of 1970. Like the Postal Service, it was defined in law as an independent establishment of the executive branch.
Keystone Bituminous Coal Ass'n v. DeBenedictis, 480 U.S. 470 (1987), is a United States Supreme Court case interpreting the Fifth Amendment's Takings Clause. In this case, the court upheld a Pennsylvania statute which limited coal mining causing damage to buildings, dwellings, and cemeteries through subsidence.
Gottschalk v. Benson, 409 U.S. 63 (1972), was a United States Supreme Court case in which the Court ruled that a process claim directed to a numerical algorithm, as such, was not patentable because "the patent would wholly pre-empt the mathematical formula and in practical effect would be a patent on the algorithm itself." That would be tantamount to allowing a patent on an abstract idea, contrary to precedent dating back to the middle of the 19th century. The ruling stated "Direct attempts to patent programs have been rejected [and] indirect attempts to obtain patents and avoid the rejection ... have confused the issue further and should not be permitted." The case was argued on October 16, 1972, and was decided November 20, 1972.
Commissioner v. Banks, 543 U.S. 426 (2005), together with Commissioner v. Banaitis, was a case decided before the Supreme Court of the United States, dealing with the issue of whether the portion of a money judgment or settlement paid to a taxpayer's attorney under a contingent-fee agreement is income to the taxpayer for federal income tax purposes. The Supreme Court held when a taxpayer's recovery constitutes income, the taxpayer's income includes the portion of the recovery paid to the attorney as a contingent fee. Employment cases are an exception to this Supreme Court ruling because of the Civil Rights Tax Relief in the American Jobs Creation Act of 2004. The Civil Rights Tax Relief amended Internal Revenue Code § 62(a) to permit taxpayers to subtract attorney's fees from gross income in arriving at adjusted gross income.
In United States federal courts, magistrate judges are judges appointed to assist U.S. district court judges in the performance of their duties. Magistrate judges generally oversee first appearances of criminal defendants, set bail, and conduct other administrative duties. The position of "magistrate judge" or "magistrate" also exists in some unrelated state courts.
United States v. Navajo Nation, 556 U.S. 287 (2009) was a United States Supreme Court case in which the Navajo Nation initiated proceedings in the Court of Federal Claims alleging that when they sought the assistance of the United States Secretary of the Interior to renegotiate their original leasing agreement with the Peabody Coal Company in 1984, a procedural process defined by the 1964 Indian Mineral Leasing Act (IMLA) of 1938, the United States Secretary of the Interior had been improperly influenced by the coal company, and as a result, had breached his fiduciary duty to the Nation when he approved the 1987 lease amendments.
Glen Morgan Williams was a United States district judge of the United States District Court for the Western District of Virginia.
Eastern Enterprises v. Apfel, 524 U.S. 498 (1998), is a United States Supreme Court case in which the Court held that the Coal Industry Retiree Health Benefit Act constituted an unconstitutional regulatory taking of property which required the Act to be invalidated. The import of this decision is that it was made in the context of a purely economic regulation. The plurality examines the statute and its resultant harm as an ad hoc factual inquiry based on factors delineated in Penn Central Transportation Co. v. New York City, such as the economic impact of the regulation, its interference with reasonable investment backed expectations, and the character of the governmental action. The decision thereby moved beyond the traditional notions of equal protection which had been applied to economic regulation since the time of Lochner v. New York, requiring extreme deference to Congress, and applied a regulatory takings analysis to the problem resulting in a much less deferential result. While the plurality recognizes that this is not a traditional takings case where the government appropriates private property for public use, they also state this is the type of case where the "Armstrong Principle" of preventing the government from forcing some people alone to bear public burdens which, in all fairness and justice, should be borne by the public as a whole. However, while the plurality seems to invalidate this particular law on takings grounds, the concurrences and the dissents warn of such an analysis as this should actually be examined under substantive due process or ex post facto theories.
The Federal Employees' Group Life Insurance Act (FEGLIA) is a United States federal statute passed by the 83rd U.S. Congress and signed into law by President Dwight D. Eisenhower on August 17, 1954. The act provided for a group life insurance policy for most federal employees, similar to those provided for employees of most large industries.
The city of Detroit, Michigan, filed for Chapter 9 bankruptcy on July 18, 2013. It is the largest municipal bankruptcy filing in U.S. history by debt, estimated at $18–20 billion, exceeding Jefferson County, Alabama's $4-billion filing in 2011. Detroit is also the largest city by population in U.S. history to file for Chapter 9 bankruptcy, more than twice as large as Stockton, California, which filed in 2012. While Detroit's population had declined from a peak of 1.8 million in 1950, its July 2013 population was reported by The New York Times as a city of 700,000.
Tyler v. Tuel, 10 U.S. 324 (1810), was a United States Supreme Court case in which the Court held that an assignee of a geographically limited patent right could not bring an action in the assignee's own name. It was the first published Supreme Court decision on patent law. Like other Supreme Court patent cases prior to Evans v. Eaton, 16 U.S. 454 (1818), however, it did not deal with substantive patent law, but only with the law of patent assignment.
United States v. Silk, 331 U.S. 704 (1947), was a United States Supreme Court case regarding US labor law. The case concerned the scope of protection for employees under the Social Security Act 1935.
The Uniformed Services Former Spouses' Protection Act is a U.S. federal law enacted on September 8, 1982 to address issues that arise when a member of the military divorces, and primarily concerns jointly-earned marital property consisting of benefits earned during marriage and while one of the spouses is a military service member. The divisibility of U.S. military retirement payments in divorce proceedings has had a turbulent legislative and legal history, and the USFSPA has not closely tracked its civilian cousin enacted in 1975, the Employee Retirement Income Security Act (ERISA), although they are similar in some respects with regard to public policy aims.
Davis v. Michigan, 489 U.S. 803 (1989), is a case in the Supreme Court of the United States holding that states may not tax federal pensions if they exempt their own state pensions from taxation. In the 1930s, the federal and state governments began to charge income tax on salaries paid to each other's employees. However, reciprocal treatment was required under the doctrine of intergovernmental immunity. The Court's ruling extended the reciprocity to pensions, since they are a form of deferred compensation for services previously rendered by an employee.