Keystone Bituminous Coal Ass'n V. de Benedictis - Procedural History

Procedural History

The District Court held that PA Coal didn't apply and that there was not a taking. Id. at 479. Finding "that the Subsidence Act served valid public purposes," the District Court determined that the Act was a legitimate exercise of the state's police power. Id. In response to the petitioners' support estate argument, the District Court found that "he support estate consists of a bundle of rights, including some that were not affected by the Act." Id. In essence, the District Court recognized that the support estate was a separate estate in land, but that the Act did not effect a taking of the whole support estate involved in this case. The District Court also rejected the Contracts Clause claim because the petitioners did not present evidence that the Act "had impaired any contract to which the Commonwealth was a party." Id. at 479-80.

The Court of Appeals found that there was not a taking and affirmed the holding of the District Court. Id. at 480. It also found that PA Coal did not apply. Id. The Court of Appeals took a different approach to analyzing the support estate than the District Court did and "onsidered the support estate as just one segment of a larger bundle of rights that invariably includes either the surface estate or the mineral estate." Id. So, instead of finding that there were three separate estates in land, the Court of Appeals decided that the support estate was not a separate estate in land. Instead, the support estate was to be included as part of the surface estate or the mineral estate. By combining the support estate with the surface estate or the mineral estate, the petitioners' "bundle of rights" became larger. Id. at 480-81. Therefore, the Court of Appeals found that "'their entire 'bundle' of property rights ha not been destroyed.'" Id. In addition, the Court of Appeals affirmed the District Court's holding concerning the Contracts Clause claim. Id. at 481.

Both lower courts cited Andrus v. Allard, 444 U.S. 51 (1979), a Supreme Court case describing the "bundle of rights" that a property owner possesses. Id. at 479-81. Relying on Andrus, both courts found that the support estate was just a "'strand'" in a larger bundle of rights. Id. According to these courts, the Act had to effect a taking of the combined bundle of the surface estate, support estate, and mineral estate to be deemed a taking.