RECOMMENDED FOR FULL-TEXT PUBLICATION

               Pursuant to Sixth Circuit Rule 206

                                

      ELECTRONIC CITATION:  1999 FED App. 0205P (6th Cir.)

                    File Name:  99a0205p.06

                                

                                

                 UNITED STATES COURT OF APPEALS

                                

                     FOR THE SIXTH CIRCUIT

                       _________________

                                



Michael H. Holland; Marty D. Hudson; Thomas

F. Connors; Robert T. Wallace, as Trustees

of the United Mine Workers of America 1992

Benefit Plan,

             Plaintiffs-Appellants,

                                           No. 97-6332 

     v.



New Era Coal Company, Inc.,

                         Defendant,



Mate Creek Development, Inc.; Sidney Coal

Company, Inc., doing business as Clean

Energy Company, Inc.,

              Defendants-Appellees.



          Appeal from the United States District Court

        for the Eastern District of Kentucky at Ashland.

   No. 94-00182 Henry R. Wilhoit, Jr., Chief District Judge.

                                

                   Argued:  February 5, 1999 

                                

                                

Page 2

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 





                Decided and Filed:  June 4, 1999

                                

Before:  JONES and SUHRHEINRICH, Circuit Judges; ECONOMUS, District Judge.{*}

                                

                        _________________



                             COUNSEL



ARGUED:  Jonathan Sokolow, UMWA HEALTH & RETIREMENT FUNDS, OFFICE OF THE GENERAL

COUNSEL, Washington, D.C., for Appellants.  Ellen S. Cappellanti, JACKSON &

KELLY, Charleston, West Virginia, Gregory B. Robertson, HUNTON & WILLIAMS,

Richmond, Virginia, for Appellees.  ON BRIEF:  Jonathan Sokolow, Larry D.

Newsome, UMWA HEALTH & RETIREMENT FUNDS, OFFICE OF THE GENERAL COUNSEL,

Washington, D.C., Linda J. Wallbaum, SEGAL, SALES, STEWART, CUTLER & TILLMAN,

Louisville, Kentucky, for Appellants.  W. Henry Jernigan, Jr., JACKSON & KELLY,

Charleston, West Virginia, Gregory B. Robertson, HUNTON & WILLIAMS, Richmond,

Virginia,  Donald P. Wagner, STOLL, KEENON & PARK, Lexington, Kentucky, for

Appellees.



                        _________________



                             OPINION

                        _________________



     SUHRHEINRICH, Circuit Judge.  Plaintiff trustees of a coal worker benefit

plan appeal from the grant of summary judgment to two Defendant coal-mine

operator employers on Plaintiffs' claim to collect payments for employee benefits 



_________________



  {*} The Honorable Peter C. Economus, United States District Judge for the

Northern District of Ohio, sitting by designation.

Page 3

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



from three Defendant employers under the Coal Industry Retiree Health Benefit

Act of 1992, 26 U.S.C.  9701-9722 ("Coal Act") (West Supp. 1998).  



     The district court found that primary liability for the employee benefit

plan contributions rested on New Era Coal Company, Inc. ("New Era"), a coal

operator that signed the 1988 National Bituminous Coal Wage Agreement

("NBCWA") and employed the coal workers for whom Plaintiffs are requesting

benefit plan contributions.  The district court found that two subsequent

coal-operators of the mine, Mate Creek Development, Inc. ("Mate Creek"), and

Sidney Coal Company, Inc. ("Sidney Creek"), doing business as Clean Energy

Mining Company ("Clean Energy"), were not liable to Plaintiffs for benefits

under the Coal Act because they had not signed the NBCWA, were not successors-

in-interest to New Era, and had not assumed any liability for New Era's

contribution to the benefit plan.  We AFFIRM the judgment of the district

court. 



          Plaintiffs raise three issues on appeal: (1) whether a transfer of stock

or assets  is necessary to be a successor-in-interest or whether merely a

substantial continuity under the totality of circumstances is sufficient; (2)

whether a successor and a successor-in-interest as that term is used in the

Coal Act are equally liable for retiree health benefits; and (3) whether the

district court failed to consider the NLRB determination that Mate Creek was a

successor-in-interest.



                          I.  BACKGROUND



                           A.  Factual



     Sidney Creek is a subsidiary of the Massey Coal Company ("Massey").  On

October 1, 1984, Sidney Creek purchased coal mines in eastern Kentucky from

Carolina Power & Light Co. ("CPL"), and two of CPL's mining subsidiaries,

Leslie Coal Mining Co., Inc. ("Leslie") and Mclnnis Coal Mining Company, Inc.

("Mclnnis").  The mines owned by Leslie and Mclnnis were operated under

collective bargaining 

Page 4

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



agreements with the United Mine Workers of America ("UMWA").  However, after

Sidney Creek acquired the mines, neither Sidney Creek nor any other Massey

company signed a collective bargaining agreement with the UMWA.  The UMWA then

struck Sidney Creek and the other non-signatory Massey companies and sued them

for violating the existing NBCWA.  The UMWA also sued Sidney Creek, Leslie,

and McInnis for violating Article I of the NBCWA.  During the strike, the

Mclnnis mine was idle.  To settle the strike in 1988, Sidney Creek paid

$4,470,000.00 to the UMWA as benefits for the strikers.  Sidney Creek also

agreed for five years to select a contractor to operate the McInnis mine who

would sign the 1988 NBCWA and hire from the strikers collectively referred to

as the "Roberts panel."



     On June 10, 1988, Sidney Creek contracted with New Era to mine coal at

the former Mclnnis mine for a fee based on production.  New Era was

incorporated in 1988, was capitalized at $500, and had no other assets.  New

Era signed the 1988 NBCWA and hired from the Roberts panel.  New Era then

operated the Mclnnis mine from June 1988 until October 1991, using Sidney

Creek's machinery, maps, and engineering services.  Sidney Creek also paid the

black lung excise tax for black lung benefits on behalf of New Era and some of

New Era's legal fees.



     In October 1991, New Era ceased operations and notified its employees

that it was terminating their medical benefits.  Sidney Creek and New Era

executed an agreement for the "orderly transition" of the operation of the

McInnis mine from New Era to Mate Creek.  Mate Creek began mining in November

1991, less than a month after New Era stopped.  As with New Era, Sidney Creek

supplied the equipment used by Mate Creek.  Mate Creek also hired from the

Roberts panel; in fact, all of the hourly employees that Mate Creek hired had

previously worked for New Era.  New Era even provided Mate Creek with its

personnel files.  Further, Mate Creek operated the McInnis mine in the same

manner as New Era had operated it. 




Page 5

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



     However, even though the 1988 Settlement Agreement required Sidney Creek

to require an operator to sign an NBCWA, Mate Creek did not sign an NBCWA or

any other agreement with the UMWA before it began mining.  Mate Creek then

unilaterally changed the terms and conditions of employment at the McInnis

mine.  The UMWA consequently filed unfair labor practice charges against Mate

Creek with the National Labor Relations Board ("NLRB").  The NLRB found that

Mate Creek was a successor to New Era, ordered Mate Creek to restore the

previous terms and conditions of employment, and to pay its obligations to the

employee benefit funds.  After the NLRB determined that Mate Creek was a

successor to New Era, Sidney Creek joined in a Settlement Agreement with the

UMWA and Mate Creek to resolve the unfair labor practice claims.  This

Settlement Agreement did not alter the NLRB's determination that Mate Creek

was New Era's successor.  Under the Settlement Agreement, Mate Creek agreed to

pay $1,000,000.00 to the UMWA and an additional amount to the UMWA 1974

Pension Trust.  Mate Creek borrowed the money from a bank, and Sidney Creek

guaranteed the loan.  Further, Sidney Creek and Mate Creek contracted for Mate

Creek to operate the Halfway Branch Mine, which Sidney Creek also owned, and

to hire its former employees at the Mclnnis mine for the Halfway Branch mine. 

Mate Creek began mining at the Halfway Branch mine in September 1994 and

stopped in January 1996. 



     After Mate Creek stopped mining at the Mclnnis mine, Sidney Creek doing

business as Clean Energy, began mining at the McInnis mine.  Sidney Creek as

Clean Energy operated the McInnis mine as New Era and Mate Creek had operated

it, using the same type of equipment, producing the same product, and selling

it to the same customers.  Clean Energy even hired six supervisors previously

employed at the mine by Mate Creek and New Era.  However, Clean Energy did not

hire Mate Creek's other employees because Mate Creek had retained them to work

at the Halfway Branch mine. 




Page 6

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



                          B.  Statutory 



     The Coal Act is the result of federal involvement in the coal industry

that began in 1946.  See generally Blue Diamond Coal Co. v. Shalala (In re

Blue diamond Coal Co.), 79 F.3d 516, 518-20 (6th Cir. 1996).  The federal

government assumed operation of the nation's coal mines during a prolonged

strike by the UMWA against coal producers.  The Krug-Lewis Agreement settled

the strike and required coal producers to provide health and pension benefits

to their workers.  After the strike in 1947, the Bituminous Coal Operators

Association, Inc. ("BCOA") and the UMWA collectively bargained for the first

NBCWA which required the coal producers to contribute a production royalty to

the UMWA Fund, a health benefit and pension fund.  Health benefits were

neither vested nor guaranteed.  Coal producers were liable to the UMWA Fund

only for their assigned royalties.



          In 1974, benefits and funding changed.  In light of the Employee

Retirement Income Security Act of 1974 (ERISA), 29 U.S.C.  1001-1461 (1994),

the UMWA Fund was divided into the 1950 UMWA Benefit Plan for older employees

and the 1974 UMWA Benefit Plan for new employees (collectively the "1974

Funds").  Under this new funding scheme, the 1974 NBCWA provided increased

benefits, including lifetime health benefits.  Later, however, the 1974 Funds

became increasingly financially unstable because many coal producers went out

of business or became non-union; many miners retired; and health care costs

increased.  



     In 1989, the UMWA struck the Pittston Coal Company for ten months over

retiree benefits.  After the Pittston strike was settled, Congress enacted the

Coal Act in 1992 to identify the payors most responsible for retirement health

care benefits.  The Coal Act consolidates the 1974 Funds into the Combined

Fund and requires all coal operators that sign a NBCWA to contribute to the

Combined Fund.  See 26 U.S.C. 

Page 7

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



 9701(a)(5), 9702, 9704, and 9705.  Under the Coal Act, beneficiaries under

the 1974 Funds are assigned to current NBCWA-signatory coal operators based on

the operators' obligations under their respective NBCWAs.  See 26 U.S.C. 

9703(f), 9706.  Eligible beneficiaries are first assigned to coal mine

operators that (1) most recently employed the beneficiary for at least two

years; and (2) signed a NBCWA in 1978 or later.  See 26 U.S.C.  9706(a)(1). 

If there is no such operator, a beneficiary is assigned to the operator that:

(1) most recently employed the beneficiary; and (2) was a signatory to the

1978 or later NBCWAs.  See 26 U.S.C.  9706(a)(2).  If there is no such

operator, the beneficiary is assigned to the beneficiaries' longest pre-1978

signatory employer.  See 26 U.S.C.  9706(a)(3).  For each beneficiary

assigned to it, an operator pays a premium to the Combined Fund.  See 26

U.S.C.  9704(a).  Each NBCWA signatory operator is also assessed for its

proportional share of unassigned or "orphan" retirees.  See 26 U.S.C. 

9704(d).  Orphan retirees are eligible beneficiaries who are not assignable

under 26 U.S.C.  9706(a) because their former employers are defunct.  See 26

U.S.C.  9703(f), 9704(d).  An operator's assigned share of orphan retirees,

for assessing premiums, is proportional to its number of beneficiaries

assigned under 26 U.S.C.  9706(a) to the total number of beneficiaries

assigned to all operators under 26 U.S.C.  9704(d), 9704(f)(1).



     The Coal Act requires the 1992 Plan to provide certain minimal benefits. 

If a liable signatory operator does not pay its proportional beneficiary

premiums, the liability is shifted, jointly and severally, to any related

person to the operator.  See 26 U.S.C.  9712(d)(4).  A related party includes

a successor-in-interest.  See 26 U.S.C.  9701(c)(2)(A), 9711(g).



                          II. DISCUSSION



     Plaintiffs argue that Mate Creek and Sidney Creek/Clean Energy  are

successors-in-interest to New Era and therefore 

Page 8

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



liable for retiree health benefits for New Era's former employees.  Plaintiffs

claim that the district court erred in holding that liability for retiree

health care premiums as a successor-in-interest under the Coal Act requires

the successor-in-interest to acquire the predecessor's assets or stocks.  



     The Coal Act imposes responsibility for funding multi-employer retiree

health benefits on the parties most responsible for plan liabilities, i.e.,

the signatory coal operators that employed the coal worker, their related

companies, and successors-in-interest.  The Coal Act does not define the term

"successor-in-interest."  However, the term is used variously in the Internal

Revenue Code ("I.R.C."), in which the Coal Act is codified, and in corporate

common law.  The case law construing successor-in-interest under the Coal Act

is meager.  A West Virginia district court held that the phrase "successor-in-

interest" in the Coal Act has the same meaning as successor-in-interest in

Treas. Reg.  1-1503-2(c)(12)(date), which deals with an acquiring corporation

in a tax-free exchange that succeeds to the tax attributes of the selling

corporation under I.R.C.  381.{1}  See UMWA 1992 Benefit Plan v. Leckie

Smokeless Coal Co., 201 B.R. 163, 179 (S.D. W. Va. 1996), aff'd, 99 F.3d 573

(4th Cir. 1996); accord, In re Lady H Coal Co., Inc. 199 B.R. 595 (S.D. W. Va.

1996).  Based on this analysis, with which we agree, the term "successor-in-

interest" requires some substantial or substantive transfer of ownership of

assets or stock.







_________________



  {1} Section 381 applies to transfer of assets (I.R.C.  368(a)(1)(D)),

liquidations of 80% owned subsidiaries (I.R.C.  332), statutory mergers and

consolidations (I.R.C.  368(a)(1)(A)), nominal changes in corporate

organization (I.R.C.  368(a)(1)(F)), exchange of assets for voting stock

(I.R.C. 368(a)(1)(C)), transfer of substantially all assets between companies

under common control, transfers of assets for stock of acquiring corporation

related corporations in a bankruptcy reorganization (I.R.C.  368(a)(1)(G)).

Page 9

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



     In contrast, Plaintiffs argue for a broad construction of "successor-in-

interest" that does not necessarily require a transfer of stocks or assets but

can rest on a substantial continuity of business operations.  They assert that

this approach is "consistent with the drafters' view that it is more

appropriate to assign the cost of providing these benefits to ongoing business

entities which have or had a relationship with the signatory employer than to

tax totally unrelated entities to fund the contractually promised benefits." 

138 Cong. Rec. S17566-01, 17603 (dailey ed. Oct. 8, 1992)(Conference Report). 

Plaintiffs contend that a common-law, multi-factor definition of "successor-

in-interest" should be used, as it is used to interpret statutes with purposes

similar to the Coal Act.  Plaintiffs rely on EEOC v. MacMillan Bloedel

Containers, Inc., 503 F.2d 1086 (6th Cir. 1974), which adopted a nine-factor

test in determining successorship under the National Labor Relations Act:



     Courts that have considered the successorship question in a labor

     context have found a multiplicity of factors to be relevant. These

     include: 1) whether the successor company had notice of the

     charge, 2) the ability of the predecessor to provide relief, 3)

     whether there has been a substantial continuity of business

     operations, 4) whether the new employer uses the same plant, 5)

     whether he uses the same or substantially the same work force, 6)

     whether he uses the same or substantially the same supervisory

     personnel, 7) whether the same jobs exist under substantially the

     same working conditions, 8) whether he uses the same machinery,

     equipment and methods of production and 9) whether he produces the

     same product.



Id. at 1094.  



     However, even under Bloedel's common-law, multi-factor analysis, it is

not clear that Mate Creek and Sidney Creek as Clean Energy are successors-in-

interest to New Era.  New Era, Mate Creek, and Clean Energy are simply

independent 

Page 10

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



coal operators who successively operated the McInnis mine under contract with

Sidney Creek, the owner of the McInnis mine.  New Era, Mate Creek, and Clean

Energy did not contract with the previous contract coal operator for the right

to operate the mine or to use the coal mining equipment.  Mate Creek did not

acquire any stock or assets, merge with New Era, nor assume any obligations of

New Era.  Mate Creek hired many of New Era's former employees because Mate

Creek hired them from the same union labor pool.  Mate Creek also did not know

of New Era's liability for retiree health benefits because Mate Creek started

operating before the Coal Act was passed in 1992.  Clean Energy is not a

successor-in-interest to Mate Creek for similar reasons. 



     Plaintiffs also claim that the Coal Act uses successor and successor-in-

interest interchangeably.  However, the Coal Act actually distinguishes

between successor and successor-in-interest in assigning liability for retiree

health benefits.  The Coal Act imposes liability for retiree health benefits

on: signatory operators, related persons, 1988 agreement operators, last

signatory operators, and assigned operators.  See 26 U.S.C.  9701(c)(1).  A

"related person" includes a successor-in-interest to any of the members of the

controlled group of corporations or other legal entities.  See 26 U.S.C.

 9701(c)(2)(A).  Similarly, 26 U.S.C.  9711(g)(1) provides: "The term 'last

signatory operator' shall include a successor in interest of such operator." 

Therefore, a successor-in-interest is liable for retiree health benefits

insofar as a related person or last signatory operator is liable.  



     However, the Coal Act treats the term successor quite differently. 

Section 26 U.S.C.  9711(g)(2) specifies that a last signatory operator "may

transfer liability" for the benefits to a successor, but that the last

signatory operator remains liable as a guarantor of the benefits.  If a

successor and successor-in-interest were synonymous, then 26 U.S.C.

 9711(g)(2) would be surplusage because a successor-in-interest already would

be statutorily liable for retiree health benefits under 26 U.S.C. 

9711(g)(1), which includes 

Page 11

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



successor-in-interest within the term last signatory operator.  However, if

successor and successor-in-interest are not synonymous, then 26 U.S.C. 

9711(g)(2) would not be surplusage.  Under a plain reading, a successor's

liability for retiree health benefits would depend on whether the last

signatory operator transferred its liability to the successor. 



     Thus, even without defining the terms successor and successor-in-

interest, the Coal Act clearly treats successors and successors-in-interest

differently.  The Coal Act imposes liability for employee-benefit

contributions on successors-in-interest, but does not similarly impose

liability on successors.  At most, New Era, Mate Creek, and Clean Energy are

successive operators of the McInnis mine.  Mate Creek and Clean Energy are not

successors-in-interest to New Era because they have no substantial or

substantive connection with each other as would be evidenced by a transfer of

stocks or assets. 



     Plaintiffs also claim that the district court erred in not deferring to

the determination of the NLRB that Mate Creek was a successor to New Era.  The

district court did not err in not deferring to the NLRB's determination

because the NLRB determined successorship for purposes of collective

bargaining, not for determining liability of retiree health benefits.  See

NLRB v. Burns Intern. Sec. Services, 406 U.S. 272 (1972) (holding that

although successor-in-interest became liable for none of predecessor's

obligations, successor-in-interest nevertheless had duty to bargain with union

under the NLRA).  Similarly here, there was no purchase of assets and stocks

or assumption of any obligations among New Era, Mate Creek, and Clean Energy. 

They were merely successive operators of the same mine, with no other

substantial connection among them.



                         III.  CONCLUSION



     We hold that liability for contributions to an employee benefit fund as

a successor-in-interest requires a transfer of 

Page 12

Holland, et al. v. New Era Coal Co., et al. 

No. 97-6332 



the predecessor's assets or stocks.  Accordingly, we AFFIRM the judgment of

the district court.