## Facts

- The Federal Coal Mine Health and Safety Act of 1969 required the Secretary of the Interior to assess civil penalties for violations of mandatory mine health and safety standards.
- The Secretary adopted regulations establishing a summary assessment process based on inspectors’ violation reports and a graduated penalty schedule.
- Mine operators had 15 working days to protest a proposed assessment and request formal administrative adjudication.
- If an operator did not timely protest, the operator was deemed to waive the right to formal adjudication and a hearing, and the proposed assessment became the Secretary’s final assessment.
- Unpaid penalties could be collected only through a civil action in federal district court, where the operator was entitled to a trial de novo as to the amount of the penalty.
- Coal mine operators and their trade association challenged the regulations, arguing that the statute required the Secretary to issue a formal decision with findings of fact in every case before any penalty could be assessed.

## Issues

1. Whether § 109(a)(3) required the Secretary to issue a decision incorporating findings of fact before assessing a civil penalty in every case, or only when an operator timely requested an administrative hearing on relevant factual issues.

## Decision

- The Supreme Court unanimously affirmed the court of appeals.
- The Court held that § 109(a)(3) requires formal findings of fact as a predicate to a penalty assessment only when the operator exercises the statutory right to request an administrative hearing.
- The Court upheld the regulations treating a failure to protest as a waiver of formal adjudication and findings.

## Legal Principles

- Statutory language granting an “opportunity for a public hearing” generally creates a right to request an evidentiary hearing rather than an automatic requirement for formal adjudication in every case.
- When no hearing is requested, an agency may rely on inspectors’ reports and scheduled criteria as a sufficient factual basis for an initial civil penalty assessment.
- A waiver-based administrative scheme is consistent with a statute providing a meaningful chance to request a hearing and preserving later judicial review before enforcement.
- Availability of a later enforcement action with trial de novo on penalty amount supports the validity of streamlined administrative assessment procedures.

## Conclusion

The Court sustained a summary civil penalty assessment system under the mine safety statute, ruling that formal findings and a hearing are required only if the operator timely requests administrative adjudication, and that nonpayment still triggers judicial proceedings with de novo review of penalty amount before enforcement.


Nat'l Indep. Coal Operators' Ass'n v. Kleppe, 423 U.S. 388 (1976)