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Yates v. Island Creek Coal Co.

Citation: 10 ELR 20692
No. No. 78-0285-B, 485 F. Supp. 995/14 ERC 1445/(W.D. Va., 03/05/1980)

Dismissing plaintiffs' suit for damages, the court finds no implied private cause of action under either the Rivers and Harbors Act or the Surface Mining Control and Reclamation Act (SMCRA) for mining activities conducted prior to its passage....

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