Kentucky Southern Coal Corp. v. Kentucky Energy & Environment Cabinet

396 S.W.3d 804, 2013 WL 1776719, 2013 Ky. LEXIS 86
CourtKentucky Supreme Court
DecidedApril 25, 2013
DocketNo. 2010-SC-000029-DG
StatusPublished
Cited by3 cases

This text of 396 S.W.3d 804 (Kentucky Southern Coal Corp. v. Kentucky Energy & Environment Cabinet) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kentucky Southern Coal Corp. v. Kentucky Energy & Environment Cabinet, 396 S.W.3d 804, 2013 WL 1776719, 2013 Ky. LEXIS 86 (Ky. 2013).

Opinions

Opinion of the Court by

Chief Justice MINTON.

The Kentucky Energy and Environment Cabinet denied Kentucky Southern Coal Corporation’s application to renew its surface and underground coal mining permit because a bona fide dispute existed over KSCC’s right of entry to 18.1 acres within the permit boundaries. The Court of Appeals affirmed the trial court, which held that the Cabinet properly denied KSCC’s renewal application. We agree that a bona fide property dispute exists, which the Cabinet had no legal authority to adjudicate. So we affirm the Court of Appeals because the Cabinet did not err in denying KSCC’s renewal permit.

I. FACTUAL AND PROCEDURAL BACKGROUND.

KSCC holds a Surface Coal Mining and Reclamation Permit over 293 acres in Kentucky, including the 18.1-acre tract of land at issue in this case. KSCC’s predecessor in interest, Norton Coal Mining Company, conveyed the surface estate of the 18.1 acres by deed to Walter Crick in 1936. The deed contained the following mineral reservation in favor of Norton:

But there is nevertheless reserved and excepted from all lands hereby conveyed all the coal and other minerals and the mining and mineral rights and privileges, the right of subjacent support, [806]*806and the rights of way for manways, air shafts, drainage shafts, drains, pipe lines, power lines, railroad and [r]ailroad switches as may be convenient or necessary for the working or development or [sic] of the Norton [c]oal [m]ines.

Crick later conveyed the surface estate to Harold and Georgia Bandy, and Norton obtained the reserved mineral estate. In December 1984, the original mining permit was issued to Norton for 29.3 acres of area mining, plus additional acreage for topsoil storage, sediment basin, and a coal-haul road, for a total of 33.1 acres of surface disturbance and 250 acres of underground mining. The 18.1-acre tract was included in the permit boundaries but could not be disturbed because it was not bonded.

Around this time, a dispute arose in which the Bandys contested Norton’s right under the Crick deed to mine the property. Norton brought suit in the Hopkins Circuit Court to quiet title to its mineral estate.1 In 1985, that court entered a judgment finding that the reservation contained in the Crick deed was effective as to the 18.1 acres. The court declared Norton “the owner of the coal and mining rights ... in and underlying the tract of land, the surface of which is owned by” the Bandys.

The judgment also granted Norton a 15-year surface lease for the Bandy property, effective January 23, 1985. Norton paid the Bandys $27,500 for the lease, which provided Norton “the right to strip mine the property and perform any mining or associated operations thereon not prohibited by this Judgment or state or federal law....” At the end of the 15-year lease, Norton was to return the leasehold to the Bandys reclaimed in accordance with state and federal regulations.

In May 1990, five years after entry of the judgment, KSCC acquired Norton’s rights in the lease over the 18.1-acre tract. Norton transferred the mining permit to KSCC; and KSCC placed the 18.1 acres under a performance bond, ensuring its reclamation.2 KSCC’s current permit includes 293 acres, of which 43 acres are surface-disturbance acres and 250 acres overlie underground operations.3 The 18.1-acre tract is a means of egress and ingress to the underground works for KSCC’s mining permit. It also includes around 17 acres of area mining and the highwall4 for the faceup to the underground mine. There is disagreement about whether the tract has been subject to surface mining operations.

In 1995, the Bandys conveyed the disputed property to Jeff and Marion Reynolds. And, in 2004, the Reynoldses conveyed the 18.1-acre tract to the current owner, Cathy Gunn.5 The surface-mining lease on the property expired at the end of the original 15-year term in January 2000 and has not been renewed.

Around late 1999 or early 2000, KSCC filed an application with the Cabinet to renew its Surface Coal Mining and Reclamation Permit for another five years. The permit is a combination underground and surface mining permit. While the applica[807]*807tion was pending, the Cabinet’s Division of Mine Permits received a protest letter from the Reynoldses claiming the 1985 surface lease between the Bandys and Norton Coal had expired and that a renewal lease had not been negotiated. KSCC did not present any further documentation of a new lease agreement and did not claim a right to enter and mine without the Reynoldses’ consent. So the Division denied KSCC’s mining license renewal application because KSCC did not prove that it had a legal right of entry and because KSCC failed diligently to pursue issuance of the renewal. KSCC then filed an amended petition, arguing for the first time that the 15-year lease applied only to strip mining and that its right of entry was based upon the terms of its broad form mineral deed and did not require consent of the surface owners.

The Division again concluded that the permit renewal should be denied because there was a bona fide dispute about KSCC’s right of entry to the surface. The dispute was submitted to the Cabinet’s hearing officer, who concluded by summary disposition that the Division properly denied KSCC’s permit renewal application because a bona fide dispute existed. The hearing officer concluded that the Hopkins Circuit Court judgment ruled that Norton owned the minerals underlying the tract of land and “went a step further and also made a determination, based upon the agreement of the parties, as to the manner in which Norton, and later, [KSCC], would have a right of entry to the surface.” The Secretary of the Cabinet issued a final order adopting the hearing officer’s recommendation and affirming the Division’s denial of the permit renewal.

KSCC sought review of the Secretary’s order in the Franklin Circuit Court, which affirmed the Cabinet’s decision. That court found that the expiration of the surface lease adjudicated by the Hopkins Circuit Court creates a bona fide dispute over the rights of KSCC to mine the coal on the 18.1-acre tract. The Court of Appeals also affirmed the Cabinet’s decision. We granted discretionary review of the case, and we now affirm.

II. ANALYSIS.

We use the substantial evidence' standard of review for an administrative agency’s findings of facts.6 “[I]f there is substantial evidence in the record to support an agency’s findings, the findings will be upheld, even though there may be conflicting evidence in the record.”7 “If the findings of fact are supported by substantial evidence of probative value, then they must be accepted as binding[;] and it must then be determined whether or not the administrative agency has applied the correct rule of law to the facts so found.”8 “When the facts are in dispute and the findings of fact by an administrative board are supported by substantial evidence, and the board [has] applied the correct rule of law to the facts so found, its final order must be affirmed.”9

A. A Bona Fide Dispute Exists Regarding KSCC’s Right of Entry to the 18.1-Acre Tract.

Kentucky Revised Statutes (KRS) 350.060(13) provides that “[a]ny valid per[808]

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Cite This Page — Counsel Stack

Bluebook (online)
396 S.W.3d 804, 2013 WL 1776719, 2013 Ky. LEXIS 86, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kentucky-southern-coal-corp-v-kentucky-energy-environment-cabinet-ky-2013.