## Facts

- Brandon Lance Rinehart held perfected federal mining claims on national forest land in Plumas County, California.
- Suction dredging removes streambed material via a high-powered hose, separates heavier minerals (including gold) through a sluice, and discharges remaining water, sand, and gravel back into the waterway.
- California historically required a state permit for suction dredging and made unpermitted suction dredging a misdemeanor.
- Due to concerns about impacts on fish habitat and water quality, California imposed a temporary moratorium on issuing suction-dredge permits pending environmental review, which effectively halted permitted suction dredging statewide.
- During the moratorium, Rinehart used a suction dredge on his federal claim without a state permit.
- Rinehart admitted the conduct but argued federal mining law preempted the state moratorium because it prevented him from using what he asserted was the only commercially practicable method to extract gold from his claim.

## Issues

1. Whether California’s temporary moratorium on suction dredge mining is preempted under obstacle preemption because it frustrates Congress’s purposes under the General Mining Law of 1872 and related federal mining statutes.
2. Whether federal mining law guarantees miners a substantive right to mine on federal claims using particular extraction methods free from state environmental regulation.

## Decision

- The California Supreme Court reversed the Court of Appeal and upheld the state moratorium against the preemption challenge.
- The court held the moratorium was not preempted by federal mining law.
- The court rejected the need for further factual development on whether suction dredging was the only commercially practicable method for Rinehart’s claim.
- The reversal reinstated the misdemeanor conviction for operating a suction dredge without a required permit during the moratorium.

## Legal Principles

- The General Mining Law of 1872 and related statutes principally secure miners’ possessory interests (and sometimes title) in mining claims; they do not confer immunity from state police-power regulation.
- In areas traditionally regulated by states, including environmental protection and wildlife and water quality regulation, courts require a clear and manifest congressional purpose to displace state law.
- Obstacle preemption applies only when state law stands as an obstacle to Congress’s objectives; the mere fact that regulation makes a mining method impracticable or unprofitable does not establish preemption absent a contrary federal command.
- Federal mining law does not guarantee a right to use any particular mineral extraction method; a state may regulate or temporarily prohibit specific methods for environmental reasons without necessarily conflicting with federal mining policy.

## Conclusion

The court held that California’s temporary suction-dredge moratorium, enacted to protect waterways and fish habitat pending environmental review, did not conflict with federal mining law because federal statutes protect mining claim possession rather than a right to mine by a preferred method free from state environmental regulation.


People v. Rinehart, 377 P.3d 818 (Cal. 2016)