People v. Rinehart: No Preemption of State Environmental Regulations under the Mining Act of 1872

In People v. Rinehart, the California Supreme Court unanimously upheld a gold miner’s criminal conviction for using a suction dredge to mine the riverbed of a waterway on federal land in violation of a state moratorium on that mining method.1 The court reversed the California Court of Appeal’s holding that the federal Mining Act of 1872 (Mining Act) preempts state regulations that render mining on federal land “commercially impracticable.”2 Focusing primarily on the text and history of the Mining Act, the California Supreme Court determined that Congress did not intend to preempt state environmental regulations on mining.3 Yet in its close examination of the Mining Act, the court avoided engaging substantially with California Coastal Commission v. Granite Rock Co., the principal U.S. Supreme Court precedent regarding state regulation of mining on federal land.4 Part I of this In Brief provides factual and legal background contextualizing Rinehart and describes the U.S. Supreme Court’s decision in Granite Rock. Part II then analyzes the Rinehart opinion, looking in particular at the California Supreme Court’s interpretation of the Mining Act and its cursory treatment of Granite Rock. Granite Rock left open significant ambiguities regarding the scope of state regulatory authority over federal lands, and Rinehart’s intense focus on the Mining Act allowed the court to circumvent Granite Rock’s difficult questions while still protecting California’s environmental regulations from the threat of federal preemption.