M.L. Johnson Family Props., LLC v. Jewell

摘要

True to its name, the exhaustion doctrine has led a seemingly simple dispute through a doctrinal obstacle course. But after the race comes the recap. According to Shawnee and Southern Ohio, administrative exhaustion is a mandatory, jurisdictional requirement under SMCRA. Although subsequent precedent—and the statute itself—seem to imply otherwise, those rulings bind the Court. And ultimately, it does not matter whether SMCRA exhaustion is jurisprudential, mandatory, jurisdictionally mandatory, or merely a claims-processing rule, because Johnson has exhausted its remedies to the extent the agency's regulations require. Thus, the Court has subject-matter jurisdiction.