Blue Diamond Coal Co. v. Shalala (In Re Blue Diamond Coal Co.)
Blue Diamond Coal Company, a Chapter 11 Debtor, challenged the constitutionality of the 'super-reachback' provision of the Coal Industry Retiree Health Benefit Act of 1992. The company argued that the Act, which required it to contribute to a Combined Fund for retired miners' health benefits despite its last UMWA contract expiring in 1964, violated the Due Process and Takings Clauses of the Fifth Amendment. The Court, applying a deferential standard for economic legislation, found a rational relationship between Blue Diamond's past conduct and the legislative goal of stabilizing health benefits. Ultimately, the Court denied Blue Diamond's motion for summary judgment and granted the motions of the Secretary of Health and Human Services and the Trustees of the Combined Fund, upholding the Coal Act's constitutionality.