ELR Citation: ELR 20692
No(s). 78-0285-B (W.D. Va. Mar 5, 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. Plaintiffs suffered injuries from a flood allegedly caus...