National Independent Coal Operators' Association v. Kleppe
United States Supreme Court
423 U.S. 388 (1976)
Under the Federal Coal Mine Health and Safety Act, assessment officers proposed civil penalties against mine operators based on inspectors' violation notices, and operators had fifteen working days to protest and request adjudication or else the proposed assessment became final by waiver. A group of mine operators (plaintiffs) challenged the Secretary of the Interior's (defendant) regulations, arguing the Act required formal findings of fact supporting any penalty regardless of whether the operator requested a hearing.
Whether, once a mine operator waives its statutory right to a hearing, the Act requires the Secretary to prepare a decision with formal findings of fact before assessing a civil penalty.