Maxxim Rebuild Co., LLC v. Mine Safety & Health Administration

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Maxxim’s Sidney, Kentucky repair shop makes and repairs mining equipment and machine parts, employing seven workers. Roughly 75% of the shop’s work is for equipment that Alpha (Maxxim’s parent company) uses to extract or prepare coal at several mines. The rest of the work is for other mining companies and for repair shops that might sell the equipment to mining or non-mining companies. The Maxxim facility does not extract coal or any other mineral, and it does not prepare coal or any other mineral for use. Sidney Coal, another Alpha subsidiary, owned the property and had an office in the upper floor of the Maxxim shop. The Mine Safety and Health Administration had asserted jurisdiction (30 U.S.C. 802(h)) over the Sidney shop and, in 2013, issued several citations. Maxxim challenged the Administration’s power to issue the citations. An administrative law judge’s ruling that the Sidney shop was “a coal or other mine” was upheld by the independent agency responsible for reviewing the Administration’s citations. The Sixth Circuit reversed. The definition of “coal or other mine” refers to locations, equipment and other things in, above, beneath, or appurtenant to active mines; the Maxxim facility is not a mine subject to the Administration’s jurisdiction. View "Maxxim Rebuild Co., LLC v. Mine Safety & Health Administration" on Justia Law