California Coastal Commission v. Granite Rock Co.

Summary

The Supreme Court held that federal statutes and Forest Service regulations did not facially preempt California's requirement that Granite Rock obtain a coastal development permit for mining on an unpatented claim in a national forest. The Court distinguished environmental regulation from land-use planning and concluded that the permit requirement could not be deemed preempted without examining the particular permit conditions imposed. The Court also held that the controversy was not moot and treated the appeal as a petition for certiorari before reversing the Ninth Circuit.

Holdings

1. The controversy was not moot because the Commission continued to assert authority over post-letter mining activity and reclamation, and Granite Rock intended to conduct future mining operations on the claims.
2. The Court lacked appellate jurisdiction under § 1254(2) because the Ninth Circuit invalidated a particular exercise of authority under state law rather than holding the state statute itself invalid. The Court treated the jurisdictional statement as a petition for certiorari.
3. Granite Rock failed to establish that any possible California Coastal Commission permit requirement was facially preempted. The Property Clause does not automatically preclude all state regulation of federal land, and the federal statutes and regulations did not demonstrate field preemption or actual conflict with every possible reasonable state environmental permit condition.

Questions Presented

1. Whether the controversy remained justiciable after Granite Rock's five-year federal plan of operations expired.
2. Whether the Supreme Court had appellate jurisdiction under 28 U.S.C. § 1254(2), or should treat the jurisdictional statement as a petition for certiorari.
3. Whether Forest Service regulations, federal mining and land-management statutes, or the Coastal Zone Management Act facially preempted California's requirement that Granite Rock obtain a coastal development permit for mining on an unpatented claim in a national forest.

Disposition

reversed_and_remanded