## Facts

- Donald and Patricia Haydo owned property with a water well that had supplied potable water for about 35 years.
- On January 18, 1984, Amerikohl Mining, Inc. began coal exploration drilling on the Haydos’ property under an assigned coal lease and option agreement.
- Shortly after drilling began, the well’s water production allegedly diminished; by June 1984 the well allegedly ran dry.
- The Haydos demanded that Amerikohl replace their water supply; Amerikohl refused.
- The Haydos sued in federal district court seeking damages, alleging the drilling violated environmental performance standards under the Surface Mining Control and Reclamation Act (SMCRA) and related Pennsylvania regulations adopted under Pennsylvania’s approved SMCRA program.

## Issues

1. Whether SMCRA’s citizen-suit provision, 30 U.S.C. § 1270, provides federal subject-matter jurisdiction over a private damages action alleging violations of a state’s SMCRA-based regulations in a state with an approved program.
2. Whether § 1270’s reference to enforcing “any rule, regulation, order, or permit issued pursuant to” SMCRA includes state regulations issued under an approved state program, or is limited to federal requirements.

## Decision

- The Third Circuit affirmed dismissal for lack of subject-matter jurisdiction.
- The court held that SMCRA did not confer federal jurisdiction for the Haydos’ damages claims premised on alleged violations of Pennsylvania’s approved program and related standards.
- The court concluded the dispute, as pleaded, belonged in state court under state law and state enforcement processes.

## Legal Principles

- Under SMCRA § 503, once a state program is approved, the state assumes exclusive jurisdiction over regulation of surface coal mining and reclamation operations on non-federal lands, subject to limited federal oversight.
- SMCRA’s citizen-suit provision authorizes federal-court enforcement of SMCRA and rules issued under SMCRA, but does not federalize private damages actions based solely on alleged violations of an approved state program.
- Alleged noncompliance with state regulations adopted pursuant to an approved SMCRA program is ordinarily enforced through state mechanisms and state courts absent an independent federal jurisdictional basis.

## Conclusion

The Third Circuit held that federal courts lack subject-matter jurisdiction under SMCRA’s citizen-suit provision over private damages claims grounded in alleged violations of a state’s approved SMCRA regulatory program, and affirmed dismissal of the Haydos’ action.


Haydo v. Amerikohl Mining, Inc., 830 F.2d 494 (3d Cir. 1987)