Thunder Basin Coal Co. v. Reich, 510 U.S. 200 (1994)

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200

OCTOBER TERM, 1993

Syllabus

THUNDER BASIN COAL CO. v. REICH, SECRETARY OF LABOR, et al.

certiorari to the united states court of appeals for the tenth circuit

No. 92-896. Argued October 5, 1993—Decided January 19, 1994

Petitioner mine operator's nonunion work force designated two employees of the United Mine Workers of America (UMWA) to serve as miners' representatives under 30 U. S. C. 813(f). Claiming that the designations compromised its rights under the National Labor Relations Act (NLRA), petitioner refused to post information about the representatives as required by a regulation issued by the Department of Labor's Mine Safety and Health Administration (MSHA), 30 CFR 40.4. Rather, petitioner filed suit in the District Court and obtained an injunction preventing enforcement of 30 CFR pt. 40. In reversing, the Court of Appeals held that district court jurisdiction was precluded by the administrative-review scheme of the Federal Mine Safety and Health Amendments Act of 1977, 30 U. S. C. 801 et seq. (Mine Act or Act), under which challenges to enforcement measures are reviewed by the Federal Mine Safety and Health Review Commission and then by the appropriate court of appeals. The court rejected petitioner's contention that requiring it to challenge the MSHA's interpretation of 30 U. S. C. 813(f) and 30 CFR pt. 40 through the statutory-review procedures would violate its rights under the Due Process Clause of the Fifth Amendment.

Held: 1. The Mine Act's statutory-review scheme precludes a district court from exercising subject-matter jurisdiction over a pre-enforcement challenge to the Act. Pp. 207-218. (a) In cases involving delayed judicial review of final agency actions, this Court finds that Congress has allocated initial review to an administrative body where such intent is fairly discernible in the statutory scheme. Whether a statute is intended to preclude initial judicial review is determined from the statute's language, structure, and purpose, its legislative history, and whether the claims can be afforded meaningful review. P. 207. (b) Although the Mine Act is facially silent about pre-enforcement claims, its comprehensive enforcement structure demonstrates that Congress intended to preclude challenges such as the present one. The

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