Cite as: 534 U. S. 438 (2002)
Opinion of the Court
The Commissioner further suggests that the Court of Appeals' construction of the statute leads to the counterintuitive result that a direct successor in interest of a signatory may not be made responsible for a signatory's beneficiaries—even though such successor liability would be supported by the background principles of successorship 16—
while a more distantly related successor in interest of a corporate affiliate of a signatory operator may be made responsible for the signatory's beneficiaries. Thus, the Commissioner appears to request that the Court invoke some form of an absurd results test. Id., at 32 (citing United States v. X-Citement Video, Inc., 513 U. S. 64, 70-71 (1994); United States v. Brown, 333 U. S. 18, 27 (1948)).17
Respondents correctly note that the Court rarely invokes such a test to override unambiguous legislation. Moreover, respondents offer several explanations for why Congress would have purposefully exempted successors in interest of a signatory operator from the "related person" definition.
16 The Commissioner asks that the Court apply the background principles of successorship, as articulated in the Court's treatment of labor, employment, and benefit statutes, that a corporate entity's liability under a statutory scheme should be attributed to the entity's direct successor in interest. Brief for Petitioner 36-40. But in the Coal Act, Congress expressly delineated those parties to which it sought to attach responsibility. Where a statute provides an explicit and all-inclusive scheme that does not include successors in interest to signatory operators, and where there is no indication that Congress intended that the statute be supplemented by reference to background principles, we will not import these principles into our analysis.
17 The dissent makes the conclusory assertion that our "interpretation of the statute . . . recreates the same difficulties that beset the NBCWAs and that Congress explicitly sought to avoid." See post, at 471. The dissent, however, provides no data for its conclusory assertion. Nor does it explain how our interpretation "recreates the same difficulties that beset the NBCWAs." Ibid. And the dissent ignores the fact that the new scheme broadly expanded the group of persons responsible for beneficiaries. Thus, the fact that Congress declined to attach liability to one group of persons tells us nothing about the new system's viability.
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