Eastern Enterprises v. Apfel
1998 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Eastern Enterprises v. Apfel, 524 U.S. 498 (1998), is a United States Supreme Court case in which the Court held that the Coal Industry Retiree Health Benefit Act (Coal Act) constituted an unconstitutional regulatory taking of property which required the Act to be invalidated.[1] The import of this decision is that it was made in the context of a purely economic regulation. The plurality examines the statute and its resultant harm as an ad hoc factual inquiry based on factors delineated in Penn Central Transportation Co. v. New York City,[2] such as the economic impact of the regulation, its interference with reasonable investment backed expectations, and the character of the governmental action. The decision thereby moved beyond the traditional notions of equal protection which had been applied to economic regulation since the time of Lochner v. New York,[3] requiring extreme deference to Congress, and applied a regulatory takings analysis to the problem resulting in a much less deferential result. While the plurality recognizes that this is not a traditional takings case where the government appropriates private property for public use, they also state this is the type of case where the "Armstrong Principle" of preventing the government from forcing some people alone to bear public burdens which, in all fairness and justice, should be borne by the public as a whole.[4] However, while the plurality seems to invalidate this particular law on takings grounds, the concurrences and the dissents warn of such an analysis as this should actually be examined under substantive due process or ex post facto theories.
Eastern Enterprises v. Apfel | |
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Argued March 4, 1998 Decided June 25, 1998 | |
Full case name | Eastern Enterprises, Petitioner v. Kenneth S. Apfel, Commissioner of Social Security, et al. |
Citations | 524 U.S. 498 (more) 118 S. Ct. 2131; 141 L. Ed. 2d 451; 1998 U.S. LEXIS 4213; 66 U.S.L.W. 4566; 22 Employee Benefits Cas. (BNA) 1225; 98 Cal. Daily Op. Service 5036; 98 Daily Journal DAR 6937; 1998 Colo. J. C.A.R. 3281; 11 Fla. L. Weekly Fed. S 755 |
Case history | |
Prior | Eastern Enterprises v. Chater, 110 F.3d 150 (1st Cir. 1997). |
Holding | |
Whether a regulatory act constitutes a taking requiring compensation depends on the extent of diminution in the value of the property. | |
Court membership | |
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Case opinions | |
Plurality | O'Connor, joined by Rehnquist, Scalia, Thomas |
Concurrence | Thomas |
Concur/dissent | Kennedy |
Dissent | Stevens, joined by Souter, Ginsburg, Breyer |
Dissent | Breyer, joined by Stevens, Souter, Ginsburg |
Laws applied | |
U.S. Const. amends. V, XIV; Coal Industry Retiree Health Benefit Act of 1992 |