Barnhart v. Peabody Coal Co.
Coal companies sought review of final orders of the Commissioner of Social Security assigning them liability for the health benefits of former employees. The Coal Industry Retiree Health Benefit Act of 1992 (Coal Act) established the United Mine Workers of America Combined Benefit Fund (Combined Fund) to ensure the continued provision of health-care benefits to retired coal miners and their dependents who worked under collective bargaining agreements that promised such benefits. Those benefits are financed principally through premiums that must be paid to the Combined Fund by ”signatory operators” that employed miners under those collective bargaining agreements and are assigned responsibility for their retired miners' benefits. The Coal Act provides that the Commissioner ”shall, before October 1, 1993,” assign responsibility for each eligible retired coal miner to the signatory operator that employed the miner (or to a ”related person” of the signatory operator). The Commissioner was unable to complete all such assignments before October 1, 1993. In a 1999 decision, the Court of Appeals for the Sixth Circuit held that the Commissioner lacked authority to make initial assignments of beneficiaries to signatory operators after October 1, 1993. Accordingly, assignments made after October 1, 1993 were declared null and void by the district court, and affirmed by the court of appeals.
Question Presented:
Whether the Commissioner's assignments of responsibility for retired miners that were made on or after October 1, 1993, are null and void.
Decision under Review (none; unpublished decision)
