## Facts

- Stearns conveyed a large tract of land in Kentucky to the United States for inclusion in a national forest, while reserving specified mineral rights in the deed.
- The reservation granted Stearns the right to mine reserved minerals and to build and use surface improvements “necessary” or “convenient” for mining, with an obligation to remove structures after mining ended.
- The deed expressly prohibited “hydraulic mining,” but did not mention strip (surface) mining.
- As surface mining became common, Stearns (or its lessees) asserted the reservation permitted strip mining to recover coal on the federal forest land.
- The United States, as surface owner, sought a declaration that the reservation did not authorize strip mining and sought to prevent that activity.
- The district court ruled for the United States, interpreting the reservation as not including strip mining and enjoining strip mining on the land.

## Issues

1. Under Kentucky law and the deed’s language, whether a mineral reservation that is silent on strip mining (and expressly excludes hydraulic mining) implies a right to conduct strip mining on land conveyed to the United States for national forest purposes.

## Decision

- The Sixth Circuit affirmed the district court’s judgment for the United States.
- The court held the deed’s mineral reservation did not include an implied right to strip mine.
- The United States, as surface owner, could bar strip mining under the deed.

## Legal Principles

- Mineral reservations are construed primarily by the deed’s specific language and the parties’ intent at the time of conveyance.
- Kentucky “broad form” deed precedents allowing later-developed extraction methods apply only where the deed uses expansive “any method” language; such precedents do not automatically expand narrower reservations.
- An express prohibition on one destructive mining technique supports a narrower construction and weighs against implying additional destructive techniques not stated.
- The mineral estate’s dominance (surface-use rights incident to mining) is limited by the reservation’s terms and does not authorize highly destructive methods absent clear contractual language.

## Conclusion

The Sixth Circuit concluded that, because the reservation used limited, specific surface-use language and expressly barred hydraulic mining while omitting any strip-mining authorization, Kentucky law did not permit implying a right to strip mine, and the United States could enjoin strip mining on the national forest land.


United States v. Stearns Coal & Lumber Co., 816 F.2d 279 (6th Cir. 1987)