ELR Citation: ELR 20762
No(s). 80-10 (E.D. Ky. Mar 31, 1982)

The court upholds the constitutionality of §518(c) of the Surface Mining Control and Reclamation Act (SMCRA), which requires prepayment of penalties into escrow prior to an evidentiary hearing. Plaintiff's petition for review of the assessed penalties was dismissed for failure to comply with §518(...