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American Mining Congress v. Mine Safety & Health Administration

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American Mining Congress v. Mine Safety & Health Administration
CourtUnited States Court of Appeals for the District of Columbia Circuit
Full case name American Mining Congress v. Mine Safety & Health Administration
ArguedNovember 10, 1992
DecidedJune 15, 1993
Citations995 F.2d 1106; 302 U.S. App. D.C. 38, 1993 O.S.H.D. (CCH) ¶ 30,096
Holding
The Program Policy letters of the mine Safety and Health Administration which stated the agency's position that certain X - Ray readings were qualified as diagnoses of lung diseases within the meaning of agency regulations were interpretive rules under the Administrative Procedure Act.
Court membership
Judges sittingStephen F. Williams, David B. Sentelle, A. Raymond Randolph
Case opinions
MajorityWilliams, joined by a unanimous court
Laws applied
Administrative Procedure Act
Keywords
Administrative Law

American Mining Congress v. Mine Safety & Health Administration, 995 F.2d 1106 (1993) is a decision by the United States Court of Appeals for the District of Columbia Circuit concerning the issues of administrative law and agency oversight.

Overview

In this case, the American Mining Congress, a miners' organizations, petitioned for review of Program Policy Letters (PPL) of Mine Safety and Health Administration, stating agency's position that certain x-ray readings qualified as diagnoses of lung disease within meaning of agency reporting regulations.

Holding

The Court was called upon to determine whether the PPL on the issue of x-rays was an interpretive rule, in which case it would be valid, or a legislative rule, in which case it would be invalid (for not being enacted in accordance with the Administrative Procedure Act). The Court used a four-part test to determine whether the rule was legislative (an affirmative answer to any one means the rule is legislative):

  1. Whether in the absence of the rule there would not be an adequate legislative basis for enforcement action or other agency action to confer benefits or ensure the performance of duties;
  2. Whether the agency has published the rule in the code of federal regulations;
  3. Whether the agency has explicitly invoked its general legislative authority;
  4. Whether the rule effectively amends a prior legislative rule. Subsequent caselaw has minimized the importance of the second factor.

References

  1. Circuit, District of Columbia (10 November 1992). "995 F2d 1106 American Mining Congress v. Mine Safety & Health Administration US American Mining Congress". p. 1106.

External links

United States federal courts
Courts of appeals
District courts
Specialty courts
Territorial courts
Extinct courts
NoteAmerican Samoa does not have a district court or federal territorial court; federal matters there go to the District of Columbia, Hawaii, or its own Supreme Court.
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