BARNHART, COMMISSIONER OF SOCIAL SECURITY v. SIGMON COAL CO., INC., et al.

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438 OCTOBER TERM, 2001
Syllabus
BARNHART, COMMISSIONER OF SOCIAL SECURITY
v. SIGMON COAL CO., INC., et al.
certiorari to the united states court of appeals for
the fourth circuit
No. 00–1307. Argued November 7, 2001—Decided February 19, 2002
The Coal Industry Retiree Health Benefit Act of 1992 (Coal Act or Act)
restructured the system for providing private health care benefits to
coal industry retirees. The Act merged the 1950 and 1974 Benefit
Plans—which were created pursuant to collective-bargaining agree-
ments between the United Mine Workers of America (UMWA) and coal
operators—into a new multiemployer plan called the UMWA Combined
Benefit Fund (Combined Fund). See 26 U. S. C. § 9702(a). That fund
is financed by annual premiums assessed against “signatory coal opera-
tors,” i. e., those who signed any agreement requiring contributions to
the 1950 or 1974 Benefit Plans. Where the signatory is no longer in
business, the Act assigns liability for beneficiaries to a defined group of
“related persons.” See §§ 9706(a), 9701(c)(2), (7). The Act charges the
Commissioner of Social Security with assigning each eligible beneficiary
to a signatory operator or its related persons, § 9706(a); identifies specific
categories of signatory operators (and their related persons) and re-
quires the Commissioner to assign beneficiaries among these categories
in a particular order, ibid.; and ensures that if a beneficiary remains
unassigned because no existing company falls within the categories,
benefits will be financed by the Combined Fund, see §§ 9704(a), (d),
9705(b). Shortly after respondent Jericol Mining, Inc. (Jericol), was
formed in 1973 as Irdell Mining, Inc., Irdell and another company pur-
chased the coal mining operating assets of Shackleford Coal Co., which
was a signatory to a coal wage agreement while it was in business.
Among other things, they assumed responsibility for Shackleford’s
collective-bargaining agreement with the UMWA. There was no com-
mon ownership between Irdell and Shackleford. Irdell subsequently
changed its name, operating as the Shackleford Coal Co. until 1977,
when it again changed its name to Jericol. Between 1993 and 1997, the
Commissioner assigned premium responsibility for 86 retired miners to
Jericol under § 9706(a)(3), determining that as a “successor” or “succes-
sor in interest” to the original Shackleford, Jericol qualified as a “related
person” to Shackleford. All of these retirees had worked for Shackle-
ford, but none of them had actually worked for Jericol. Jericol and re-
spondent Sigmon Coal Company, Inc., a person related to Jericol under

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439 Cite as: 534 U. S. 438 (2002)
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§ 9701(c)(2), filed suit against the Commissioner. The District Court
granted them summary judgment, concluding that the Act’s classifica-
tion regime does not provide for the liability of successors of defunct
signatory operators. In affirming, the Fourth Circuit concluded that
the Act was clear and unambiguous and that the court was bound to
read it exactly as it was written, and held, inter alia, that Jericol was
not a “related person” to Shackleford and thus could not be held respon-
sible for Shackleford’s miners.
Held: The Coal Act does not permit the Commissioner to assign retired
miners to the successors in interest of out-of-business signatory opera-
tors. Pp. 450–462.
1. Because the Act is explicit as to who may be assigned liability for
beneficiaries and neither the “related persons” provision nor any other
provision states that successors in interest to these signatory operators
may be assigned liability, the Act’s plain language necessarily precludes
the Commissioner from assigning the disputed miners to Jericol.
Where, as here, the statutory language is unambiguous, the inquiry
ceases. See, e. g., United States v. Ron Pair Enterprises, Inc., 489 U. S.
235, 240. Since the retirees at issue were Shackleford employees, the
“signatory operator” that sold its assets to Jericol (then-Irdell) in 1973,
the Commissioner can only assign the beneficiaries to Jericol if it is
a “related person” to Shackleford under § 9706(a). Section 9701(c)(2)
states that “[a] person shall be considered to be a related person to a
signatory operator if that person is—” “(i) a member of the controlled
group of corporations . . . which includes [the] signatory operator”; “(ii)
a trade or business . . . under common control . . . with such signatory
operator”; or “(iii) any other person who [has] a partnership interest or
joint venture with a signatory operator” with some exceptions. A re-
lated person also includes “a successor in interest of any person de-
scribed in clause (i), (ii), or (iii).” There is no contention that Jericol
was ever a member of a controlled group of corporations including
Shackleford, that it was ever a business under common control with
Shackleford, or that it ever had a partnership interest or engaged in a
joint venture with Shackleford. Therefore, liability for these benefi-
ciaries may attach to Jericol only if it is a successor in interest to an
entity described in §§ 9701(c)(2)(A)(i)–(iii). Because Jericol is a succes-
sor in interest only to Shackleford, Jericol will be liable only if a signa-
tory operator itself, here Shackleford, falls within one of these catego-
ries. None of the three categories, however, includes the signatory
operator itself. Nor should such inclusion be inferred, since it is a gen-
eral principle of statutory construction that when one statutory section
includes particular language that is omitted in another section of the

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440 BARNHART v. SIGMON COAL CO.
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same Act, it is presumed that Congress acted intentionally and pur-
posely. E. g., Russello v. United States, 464 U. S. 16, 23. Where Con-
gress wanted to provide for successor liability in the Coal Act, it did so
explicitly, as demonstrated by §§ 9706(b)(2) and 9711(g)(1). If Congress
had meant to make a preenactment successor in interest like Jericol
liable, it could have done so clearly and explicitly. Pp. 450–454.
2. The Court rejects the Commissioner’s arguments that, in light of
the Coal Act’s text, structure, and purposes, a direct successor in inter-
est of the entity that was the signatory operator is included within the
liability scheme and should be responsible for that operator’s Combined
Fund premiums if the operator is defunct and there is no other “related
person” still in business. Pp. 454–462.
(a) The Act’s text supports neither of two readings proposed by
the Commissioner. First, the Commissioner argues that, because
§ 9701(c)(2)(A)’s last sentence states that “related person” “include[s]” a
successor in interest of “any person described in clause (i), (ii), or (iii),”
and because these clauses mention the “signatory operator” itself, that
operator is “described” in clause (i) by virtue of the express reference.
It is unlikely that Congress, which neither created a separate category
for signatory operators nor included signatory operators within the cat-
egories, intended to attach liability to a group such as successors in
interest to signatory operators through a general clause that was meant
to reach persons “described” in one of three explicit categories. Sec-
ond, the Commissioner argues that, because a signatory operator is nec-
essarily a member of a controlled group of corporations that includes
itself under § 9701(c)(2)(A)(i), a “successor in interest” of a member of
that group includes a successor in interest of the signatory operator.
Section 9701(c)(2)(A)(i), however, cannot be divorced from the clause
that begins the related persons provision: “A person shall be considered
to be a related person to a signatory operator if that person is—.”
§ 9701(c)(2)(A) (emphasis added). Because it makes little sense for a
signatory operator to be related to itself, the statute necessarily implies
that a “related person” is a separate entity from a signatory operator.
Moreover, the Commissioner’s argument only works where the signa-
tory operator is actually part of a “controlled group of corporations.”
The argument has no force here, in any event, because the Commis-
sioner does not contend that Shackleford was part of such a group.
Pp. 455–456.
(b) The floor statements of two Senators who sponsored the Coal
Act, which the Commissioner alleges support her position, cannot amend
the unambiguous language of the statute. There is no reason to give
greater weight to a Senator’s floor statement than to the collective votes

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441 Cite as: 534 U. S. 438 (2002)
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of both Houses, which are memorialized in the unambiguous statutory
text. Pp. 456–457.
(c) Also unavailing is the Commissioner’s argument that construing
the “related person” provision to exclude a signatory’s direct successor
in interest would be contrary to Congress’ stated purposes of ensuring
that each Combined Fund beneficiary’s health care costs are borne (if
possible) by the person with the most direct responsibility for the bene-
ficiary, not by persons that had no connection with the beneficiary or by
the public fisc. The Commissioner appears to request application of
some form of an absurd results test. Respondents answer correctly
that this Court rarely invokes such a test to override unambiguous legis-
lation, and offer several explanations for why Congress would have pur-
posefully exempted successors in interest of a signatory operator from
the “related person” definition. Where the statutory language is clear
and unambiguous, this Court need neither accept nor reject a particular
“plausible” explanation for why Congress would have written a statute
as it did. Negotiations surrounding the bill’s enactment tell a typical
story of legislative battle among interest groups, Congress, and the
President. It is quite possible that a bill that assigned liability to suc-
cessors of signatory operators would not have survived the legislative
process. The deals brokered during a Committee markup, on the floor
of the two Houses, during a joint House and Senate Conference, or in
negotiations with the President are not to be second-guessed by this
Court, whose role is to interpret the language of the statute enacted by
Congress. The Court will not alter unambiguous text in order to sat-
isfy the Commissioner’s policy preferences. Pp. 458–462.
(d) Finally, the Court rejects the Commissioner’s suggestion that,
because it was reasonable for her to conclude that direct successors of
a signatory operator should be responsible for the operator’s employees,
her interpretation is entitled to deference. In the context of an un-
ambiguous statute, this Court need not contemplate deferring to an
agency’s interpretation. See Chevron U. S. A. Inc. v. Natural Re-
sources Defense Council, Inc., 467 U. S. 837, 842–843. P. 462.
226 F. 3d 291, affirmed.
Thomas, J., delivered the opinion of the Court, in which Rehnquist,
C. J., and Scalia, Kennedy, Souter, and Ginsburg, JJ., joined. Ste-
vens, J., filed a dissenting opinion, in which O’Connor and Breyer, JJ.,
joined, post, p. 462.
Paul R. Q. Wolfson argued the cause for petitioner. With
him on the briefs were Solicitor General Olson, Acting As-

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442 BARNHART v. SIGMON COAL CO.
Opinion of the Court
sistant Attorney General Schiffer, Deputy Solicitor General
Kneedler, Mark B. Stern, and Jeffrey Clair.
Peter Buscemi argued the cause for the Trustees of the
United Mine Workers of America Combined Benefit Fund as
amici curiae urging reversal. With him on the brief were
John R. Mooney, Mark J. Murphy, and David W. Allen.
John R. Woodrum argued the cause for respondents.
With him on the briefs was Harold R. Montgomery.*
Justice Thomas delivered the opinion of the Court.
This case arises out of the Commissioner of Social Secu-
rity’s assignment, pursuant to the Coal Industry Retiree
Health Benefit Act of 1992 (Coal Act or Act), 26 U. S. C.
§ 9701 et seq. (1994 ed. and Supp. V), of 86 retired coal miners
to the Jericol Mining, Inc. (Jericol). The question presented
is whether the Coal Act permits the Commissioner to assign
retired miners to the successors in interest of out-of-business
signatory operators.1 The United States Court of Appeals
for the Fourth Circuit held that it does not. Sigmon Coal
Co. v. Apfel, 226 F. 3d 291 (2000). We affirm.
I
The Coal Act reconfigured the system for providing pri-
vate health care benefits to retirees in the coal industry. In
restructuring this system, Congress had to contend with
*Grant Crandall filed a brief for the United Mine Workers of America
as amicus curiae urging reversal.
Briefs of amici curiae urging affirmance were filed for the Bellaire
Corp. by Donald B. Ayer, Jonathan C. Rose, and Thomas A. Smock; for
R. G. Johnson Co., Inc., by Mary Lou Smith; and for USX Corp. et al. by
David J. Laurent.
1 A signatory operator is a “coal operato[r] that signed any [National
Bituminous Coal Wage Agreement] or any other agreement requiring con-
tributions to the 1950 or 1974 Benefit Plans.” Eastern Enterprises v.
Apfel, 524 U. S. 498, 514 (1998); see also 26 U. S. C. § 9701(c)(1) (1994 ed.)
(“The term ‘signatory operator’ means a person which is or was a signa-
tory to a coal wage agreement”).

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over half a century of collective-bargaining agreements
between the coal industry and the United Mine Workers
of America (UMWA), the coal miners’ union. Tensions
between coal operators and the UMWA had often led to
lengthy strikes with serious economic consequences for both
the industry and its employees. Confronted with an indus-
try fraught with contention, Congress was faced with a diffi-
cult task.2
This was not the first time that the Federal Government
had been called on to intervene in negotiations within the
industry. Such tensions motivated President Truman, in
1946, to issue an Executive Order directing the Secretary of
the Interior to take possession of all bituminous coal mines
and to negotiate with the UMWA over changes in the terms
and conditions of miners’ employment. See Eastern Enter-
prises v. Apfel, 524 U. S. 498, 504–505 (1998) (plurality opin-
ion) (quoting 11 Fed. Reg. 5593 (1946)). These negotiations
culminated in the first of many agreements that resulted in
the creation of benefit funds compensating miners, their de-
pendents, and their survivors. 524 U. S., at 505.
Subsequently, in 1947, the UMWA and several coal opera-
tors entered into a collectively bargained agreement, the Na-
tional Bituminous Coal Wage Agreement (NBCWA), which
established a fund under which three trustees “were given
authority to determine,” among other things, the allocation
of benefits to miners and their families. Id., at 505–506.
Further disagreement prompted the parties to negotiate an-
other NBCWA in 1950. The following year, the Bituminous
Coal Operators’ Association (BCOA) was created as a multi-
employer bargaining association and primary representative
for the coal operators in their negotiations with the UMWA.
Id., at 506.
2 In Eastern Enterprises, 524 U. S., at 504–514, we discussed at great
length the history of negotiations between the coal industry and the
UMWA over the provision of employee benefits to coal miners. We pro-
vide only a brief summary here.

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While the NBCWA was amended occasionally and new
NBCWAs were adopted in 1968 and 1971, the terms and
structure of the 1950 agreement remained largely unchanged
between 1950 and 1974. Ibid. In 1974, in order to comply
with the Employee Retirement Income Security Act of 1974,
29 U. S. C. § 1001 et seq. (1994 ed. and Supp. V), the UMWA
and the BCOA negotiated a new agreement to finance bene-
fits. 524 U. S., at 509. The 1974 NBCWA created four
trusts that replaced the 1950 fund.3
These benefit plans quickly developed financial problems.
Thus, in 1978 the parties executed another NBCWA. This
agreement assigned responsibility for the health care of
active and retired employees to the respective coal mine
operators who were signatories to the earlier NBCWAs, and
left the 1974 Benefit Plan in effect only for those retirees
whose former employers were no longer in business. Id.,
at 510.
Nonetheless, financial problems continued to plague the
plans “as costs increased and employers who had signed the
1978 NBCWA withdrew from the agreement, either to con-
tinue in business with nonunion employees or to exit the coal
business altogether.” Id., at 511. “As more and more coal
operators abandoned the Benefit Plans, the remaining signa-
tories were forced to absorb the increasing cost of covering
retirees left behind by exiting employers.” Ibid. Pursuant
to yet another NBCWA, the UMWA and the BCOA in 1988
attempted to remedy the problem, this time by imposing
withdrawal liability on NBCWA signatories that seceded
from the benefit plans.
Despite these efforts, the plans remained in serious finan-
cial crisis and, by June 1991, the 120,000 individuals who
3 These trusts included the UMWA 1950 Benefit Plan and Trust (1950
Benefit Plan), which provided nonpension benefits including medical bene-
fits for miners who retired before January 1, 1976, and the UMWA 1974
Benefit Plan and Trust (1974 Benefit Plan), which provided such benefits
for active miners and those who retired after 1975. Id., at 509.

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received health benefits from the funds were in danger of
losing their benefits. Frieden, Congress Ponders Fate of
Coal Miners’ Fund, 10 Business & Health 65 (Sept. 1992)
(hereinafter Frieden). About 60% of these individuals were
retired miners and their dependents whose former em-
ployers were no longer contributing to the benefit plans.
Another 15% worked for employers that were no longer
UMWA-represented or were never unionized. 4 Karr,
Union, Nonunion Coal Companies Head for Showdown on
Retirement Benefits, Wall Street Journal, Mar. 3, 1992, p. A6
(hereinafter Karr). These troubles were further aggra-
vated by rising health care costs. Frieden 65.
The UMWA threatened to strike if a legislative solution
was not reached. Karr A6. And BCOA members, which
included those coal firms that were currently signatories to
NBCWAs, threatened that they would not renew their com-
mitments to cover retiree costs when their contracts expired.
Ibid. Following another strike and much unrest, Secretary
of Labor Elizabeth Dole created the Advisory Commission
on United Mine Workers of America Retiree Health Benefits
(Coal Commission), which studied the problem and proposed
several solutions. Eastern Enterprises, 524 U. S., at 511–
512. In particular, the Coal Commission focused on how to
finance the health care benefits of orphaned retirees.
Congress considered these and other proposals and even-
tually reconfigured the allocation of health benefits for coal
miner retirees by enacting the Coal Act in 1992. Crafting
the legislative solution to the crisis, however, was no easy
task. The Coal Act was passed amidst a maelstrom of con-
4 The term “orphan retirees” encompassed both “true orphans,” whose
former employers were no longer in business, and “reachback orphans,”
whose former employers were still in business but no longer signatories
to a coal wage agreement and possibly no longer in the coal business.
House Committee on Ways and Means, Development and Implementation
of the Coal Industry Retiree Health Benefit Act of 1992, 104th Cong., 1st
Sess., 1 (Comm. Print 1995) (hereinafter Development).

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446 BARNHART v. SIGMON COAL CO.
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tract negotiations, litigation,5 strike threats, a Presidential
veto of the first version of the bill 6 and threats of a second
veto, and high pressure lobbying,7 not to mention wide dis-
agreements among Members of Congress.
5 See, e. g., McGlothlin v. Connors, 142 F. R. D. 626 (WD Va. 1992). This
lawsuit involved the beneficiaries of the 1950 Benefit Plan and the 1974
Benefit Plan, the trustees, and the BCOA. The District Court Judge en-
couraged them to “zealously seek passage of a bill in Congress to permit
the transfer of other funds now in the possession of the Trustees, which
are in excess of any future projected needs, to finance the Benefit Trusts.”
Id., at 646.
6 Under the original proposal, introduced by Senator Jay Rockefeller,
benefits would have been financed through taxes on the entire coal indus-
try and premiums collected from reachback companies that were consid-
ered responsible for specific orphans. Development 12. With support
from both the UMWA and the BCOA, but not the Private Benefits Alli-
ance (PBA), a group of nonunion companies, Congress originally passed
this bill as part of a comprehensive tax package. See Karr A6. Presi-
dent Bush, however, vetoed the entire package, in part because of the coal
tax provisions. Tax Package Veto Kills Bailout Plan; Rockefeller Vows
to Find Another Way, Mine Regulation Reporter, Mar. 27, 1992, 1992 WL
2219562. Members of Congress continued to push for legislation, using
a comprehensive energy bill as the vehicle. While Senator Rockefeller
attempted to add the coal tax provision to the energy bill, his measure was
strongly opposed by a number of Senators and by the Bush administration.
Cloture Motion on Energy Bill Fails but Dole Says Resolution of Dispute
Over Controversial Coal Tax May Be Near; Bush Threatens Veto if it
Remains, Foster Natural Gas Report, No. 1886, July 23, 1992, p. 1. After
much negotiation, the final version of the bill did not include the
tax provision and provided that only companies that were party to the
NBCWAs would be required to cover retiree health costs. Senate Adopts
Compromise Amendment on Funding of Miner Health Benefits, 147 BNA
Daily Labor Report No. 147, p. A–12 (July 30, 1992).
7 The UMWA and the BCOA, for example, had joined forces to support
legislation that would require nonunion companies to share in the cost of
providing the health benefits, thereby shifting the burden of paying into
the funds to the entire industry. By contrast, the PBA, the alliance of
nonunion companies, insisted that because they never employed any of
the retirees, they should not be forced to pick up the other companies’
obligations. Karr A6.

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The Act “merged the 1950 and 1974 Benefit Plans into a
new multiemployer plan called the United Mine Workers of
America Combined Benefit Fund (Combined Fund).” Id., at
514; see 26 U. S. C. § 9702(a) (1994 ed.). The Combined Fund
“is financed by annual premiums assessed against ‘signatory
coal operators,’ i. e., coal operators that signed any NBCWA
or any other agreement requiring contributions to the 1950
or 1974 Benefits Plans.” Eastern Enterprises, 524 U. S., at
514. Where the signatory is no longer in business, the stat-
ute assigns liability for beneficiaries 8 to a defined group of
“related persons.” Ibid.; see §§ 9706(a), 9701(c)(2), (7). The
Coal Act charged the Commissioner of Social Security with
assigning each eligible beneficiary to a signatory operator or
its related persons. § 9706(a). The statute identifies spe-
cific categories of signatory operators (and their related per-
sons) and requires the Commissioner to assign beneficiaries
among these categories in a particular order. Ibid. The
Coal Act also ensures that if a beneficiary remains unas-
signed because no existing company falls within the afore-
mentioned categories, then benefits will be financed by the
Combined Fund, either with funds transferred from interest
earned on the Department of the Interior’s Abandoned Mine
Reclamation Fund or from an additional premium imposed
on all assigned signatory operators on a pro rata basis. See
§§ 9704(a), (d), 9705(b).
II
Respondent Jericol was formed in 1973 as Irdell Mining,
Inc. (Irdell). Shortly thereafter, Irdell and another com-
pany purchased the coal mining operating assets of Shackle-
ford Coal Company, a company that was a signatory to a coal
8 The term “beneficiary” refers to an individual who “(1) is a coal indus-
try retiree who, on July 20, 1992, was eligible to receive, and receiving,
benefits from the 1950 UMWA Benefit Plan or the 1974 UMWA Benefit
Plan, or (2) on such date was eligible to receive, and receiving, benefits
in either such plan by reason of a relationship to such retiree.” § 9703(f).

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448 BARNHART v. SIGMON COAL CO.
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wage agreement while it was in business. Sigmon Coal Co.
v. Apfel, 33 F. Supp. 2d 505, 507 (WD Va. 1998). They ac-
quired the right to use the Shackleford name and assumed
responsibility for Shackleford’s outstanding contracts, includ-
ing its collective-bargaining agreement with the UMWA.
App. 23–24, 26. “There was no common ownership between
Irdell and Shackleford.” 226 F. 3d, at 297. Irdell subse-
quently changed its name, operating as the Shackleford Coal
Company until 1977, when it again changed its name to Jeri-
col. The new company was a signatory only to the 1974
NBCWA.
Acting pursuant to § 9706(a), between 1993 and 1997, the
Commissioner assigned premium responsibility for over 100
retired miners and dependents to Jericol. Of these, 86 were
assigned under § 9706(a)(3) because they had worked for
Shackleford and the Commissioner determined that as a
“successor” or “successor in interest” to the original Shackle-
ford, Jericol qualified as a “related person” to Shackleford.
The others were assigned because they had actually worked
for Jericol. Jericol appealed most of the Commissioner’s de-
terminations,9 arguing that the assignments were erroneous
both because Jericol was not a successor in interest to Shack-
leford and because Jericol was not a related person to Shack-
leford.10 See, e. g., Pet. for Cert. 45a–62a.
Dissatisfied with the outcome of administrative proceed-
ings, respondent Sigmon Coal Company, Inc.,11 and Jericol
9 Jericol did not appeal the most recent 1997 assignment to the Commis-
sioner, arguing that it had already filed suit and should not be required to
exhaust its administrative remedies before seeking relief given the simi-
larity of the law and facts underlying each assignment of Shackleford’s
miners to Jericol. The District Court agreed. Sigmon Coal Co. v. Apfel,
33 F. Supp. 2d 505, 508 (WD Va. 1998).
10 In this case, we are only reviewing whether Jericol is a related person
to Shackleford.
11 Sigmon Coal joined Jericol as a plaintiff apparently because they are
related persons under the Coal Act, 26 U. S. C. § 9701(c)(2) (1994 ed.), and
thus jointly and severally responsible for any amounts due from either.
§ 9704(a). See 33 F. Supp. 2d, at 506, n. 3.

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filed suit against the Commissioner, arguing that he wrong-
fully assigned retirees and dependents to Jericol. 33 F.
Supp. 2d, at 506. The District Court concluded that the
classification regime of the Coal Act does not provide, di-
rectly or indirectly, “for liability to be laid at the door of
successors of defunct signatory operators.” Id., at 509.
The District Court ordered the Commissioner to withdraw
the challenged assignments and enjoined the Commissioner
from assigning additional retirees to Jericol on the basis that
it is a related person to the original Shackleford.
The Commissioner appealed, arguing that a “straight read-
ing” of the statute shows that a successor in interest to a
signatory operator qualifies as a related person, thereby per-
mitting the assignment of the retirees and dependents to
Jericol. 226 F. 3d, at 303. Alternatively, the Commissioner
argued that the District Court’s “reading . . . produces
inexplicable, anomalous results that are clearly at odds with
congressional intent.” Ibid.
“[D]eclin[ing] the Commissioner’s invitation to rewrite the
Coal Act,” the United States Court of Appeals for the Fourth
Circuit affirmed. Id., at 294. The Court of Appeals con-
cluded that the “statute is clear and unambiguous” and that
the court was “bound to read it exactly as it is written.”
Ibid. Accordingly, the court held that Jericol was not a “re-
lated person” to Shackleford and thus could not be held re-
sponsible for Shackleford’s miners. The Court of Appeals
rejected the Commissioner’s arguments that this reading
either contravenes congressional intent or begets “some
fairly odd results.” Id., at 305, 307. Rather, the Court of
Appeals found plausible Jericol’s explanation that the plain
text of the Act was consistent with Congress’ desire to pro-
mote the sale of coal companies and to respond to complaints
by coal operators that they were being required to pay bene-
fits for retired miners who had neither worked for them nor
maintained any other relationship with them. Id., at 307.
A plausible explanation, the court concluded, “is all we need

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450 BARNHART v. SIGMON COAL CO.
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to reject the assertion that the Coal Act’s definition of ‘re-
lated person’ is, on its face, absurd.” Id., at 308. Alterna-
tively, the court reasoned, even if the literal text of the stat-
ute produced an arguably anomalous result, “we are not
simply free to ignore unambiguous language because we can
imagine a preferable version.” Ibid. This was not one of
those rare cases, the court concluded, where Congress had
drafted a statute that “produced an absurdity ‘so gross as to
shock the general moral or common sense.’ ” Ibid. (quoting
Maryland Dept. of Ed. v. Department of Veterans Affairs,
98 F. 3d 165, 169 (CA4 1996)).
We granted certiorari, 532 U. S. 993 (2001), and now affirm.
III
As in all statutory construction cases, we begin with the
language of the statute. The first step “is to determine
whether the language at issue has a plain and unambiguous
meaning with regard to the particular dispute in the case.”
Robinson v. Shell Oil Co., 519 U. S. 337, 340 (1997) (citing
United States v. Ron Pair Enterprises, Inc., 489 U. S. 235,
240 (1989)). The inquiry ceases “if the statutory language
is unambiguous and ‘the statutory scheme is coherent and
consistent.’ ” 519 U. S., at 340.
With respect to the question presented in this case, this
statute is unambiguous. The statutory text instructs that
the Coal Act does not permit the Commissioner to assign
beneficiaries to the successor in interest of a signatory opera-
tor. The statute provides:
“For purposes of this chapter, the Commissioner of
Social Security shall, before October 1, 1993, assign each
coal industry retiree who is an eligible beneficiary to a
signatory operator which (or any related person with
respect to which) remains in business in the following
order:
“(1) First, to the signatory operator which—

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“(A) was a signatory to the 1978 coal wage agreement
or any subsequent coal wage agreement, and
“(B) was the most recent signatory operator to em-
ploy the coal industry retiree in the coal industry for at
least 2 years.
“(2) Second, if the retiree is not assigned under para-
graph (1), to the signatory operator which—
“(A) was a signatory to the 1978 coal wage agreement
or any subsequent coal wage agreement, and
“(B) was the most recent signatory operator to em-
ploy the coal industry retiree in the coal industry.
“(3) Third, if the retiree is not assigned under para-
graph (1) or (2), to the signatory operator which em-
ployed the coal industry retiree in the coal industry for
a longer period of time than any other signatory opera-
tor prior to the effective date of the 1978 coal wage
agreement.” 26 U. S. C. § 9706(a) (1994 ed.).
In this case, the Commissioner determined that because
Shackleford is a pre-1978 signatory and employed the dis-
puted miners for over 24 months, assignment must be made
under category 3. It then assigned the miners to Jericol
after determining that Jericol was a successor in interest to
Shackleford and was therefore a “related person” to Shackle-
ford. 226 F. 3d, at 298.
We disagree with the Commissioner’s reasoning. Because
the disputed retirees were employees of Shackleford, the
“signatory operator” that sold its assets to Jericol (then-
Irdell) in 1973, the Commissioner can only assign them to
Jericol if it is a “related person” to Shackleford. The statute
provides that “a person shall be considered to be a related
person to a signatory operator if that person” falls within
one of three categories:
“(i) a member of the controlled group of corporations
(within the meaning of section 52(a)) which includes such
signatory operator;

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452 BARNHART v. SIGMON COAL CO.
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“(ii) a trade or business which is under common
control (as determined under section 52(b)) with such
signatory operator; or
“(iii) any other person who is identified as having a
partnership interest or joint venture with a signatory
operator in a business within the coal industry, but only
if such business employed eligible beneficiaries, except
that this clause shall not apply to a person whose only
interest is as a limited partner.” § 9701(c)(2).
In addition, the last sentence of § 9701(c)(2)(A) states that
“[a] related person shall also include a successor in interest
of any person described in clause (i), (ii), or (iii).”
Although the Commissioner maintains that Jericol is a “re-
lated person” to Shackleford, Jericol does not fall within any
of the three specified categories defining a “related person.”
There is no contention that it was ever a member of a con-
trolled group of corporations including Shackleford, that it
was ever a business under common control with Shackleford,
or that it ever had a partnership interest or engaged in a
joint venture with Shackleford. Therefore, liability for
these beneficiaries may attach to Jericol only if it is a succes-
sor in interest to an entity described in §§ 9701(c)(2)(A)(i)–
(iii). Because Jericol is a successor in interest only to
Shackleford, Jericol will be liable only if a signatory operator
itself, here Shackleford, falls within one of these categories.
None of the three categories, however, includes the signatory
operator itself.
Nor should we infer as much, as it is a general principle of
statutory construction that when “ ‘Congress includes partic-
ular language in one section of a statute but omits it in an-
other section of the same Act, it is generally presumed that
Congress acts intentionally and purposely in the disparate
inclusion or exclusion.’ ” Russello v. United States, 464
U. S. 16, 23 (1983) (quoting United States v. Wong Kim Bo,
472 F. 2d 720, 722 (CA5 1972)). Where Congress wanted to
provide for successor liability in the Coal Act, it did so explic-

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Opinion of the Court
itly, as demonstrated by other sections in the Act that give
the option of attaching liability to “successors” and “succes-
sors in interest.”
For example, § 9706(b)(2) provides that with respect to
beneficiaries of the Combined Fund, “[i]f a person becomes a
successor of an assigned operator after the enactment date
[of the Coal Act], the assigned operator may transfer the
assignment of an eligible beneficiary . . . to such successor,
and such successor shall be treated as the assigned operator
with respect to such eligible beneficiary for purposes of this
chapter.” (Emphasis added.) The subsection also pro-
vides, however, that “the assigned operator transferring
such assignment (and any related person) shall remain the
guarantor of the benefits provided to the eligible beneficiary
under this chapter.” Ibid. While this provision gives a
postenactment successor the option of transferring the as-
signment and assuming the signatory operator’s liability, it
does not address the liability of preenactment successors.
Further, § 9711 enumerates the continuing obligations of
Individual Employer Plans (IEPs) maintained pursuant
to a 1978 or subsequent coal wage agreement.12 Section
9711(g)(1) provides that “[f]or [the] purposes of ” IEPs and
the 1992 UMWA Benefit Plan, “[t]he term ‘last signatory op-
erator’ shall include a successor in interest of such operator.”
Thus, in § 9711, Congress gave “last signatory operator” a
subsection-specific definition that extends the IEP obliga-
tions of a preenactment signatory operator to include its
“successors in interest.”
Those subsections stand in direct contrast to the provi-
sions implicated here: §§ 9701(c)(1), (2), and (4), which define
“signatory operator,” “related persons,” and “last signatory
operator,” respectively, “[f]or [the] purposes of this section,”
12 The rules applicable to successors of signatory operators who maintain
such plans are provided in §§ 9711(g)(1) and (2); § 9711(g)(2) discusses the
obligations of a person who becomes a successor of a last signatory opera-
tor postenactment, and is nearly identical to § 9706(b)(2).

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and do not specify that they include or impose liability on
the signatory operator’s successor in interest.
Despite the unambiguous language of the statute with re-
spect to those entities to whom successor liability attaches,
the Commissioner essentially asks that we read into the stat-
ute mandatory liability for preenactment successors in inter-
est to signatory operators. This we will not do. “We re-
frain from concluding here that the differing language in the
two subsections has the same meaning in each. We would
not presume to ascribe this difference to a simple mistake in
draftsmanship.” Russello, supra, at 23. Congress wrote
the statute in a manner that provides for liability only for
successors in interest to certain signatory operators. If
Congress meant to make a preenactment successor in inter-
est like Jericol liable, it could have done so clearly and
explicitly.
Therefore, because the statute is explicit as to who may
be assigned liability for beneficiaries and neither the “related
persons” provision nor any other provision states that suc-
cessors in interest to signatory operators may be assigned
liability, the plain language of the statute necessarily pre-
cludes the Commissioner from assigning the disputed miners
to Jericol.
IV
The Commissioner admits that the “statute does not state
in haec verba that an assignment may be made to a direct
successor in interest of the entity that was the signatory
operator itself.” Brief for Petitioner 10. Nonetheless, the
Commissioner concludes that, in light of the text, structure,
and purposes of the Coal Act, such direct successors in inter-
est are included within the liability scheme and should be
responsible for a signatory operator’s Combined Fund premi-
ums if the signatory operator itself is defunct and there is
no other “related person” still in business. Ibid. We ad-
dress the Commissioner’s arguments below.

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A
The Commissioner proposes several readings of the stat-
ute. First, the Commissioner argues that, because the last
sentence of § 9701(c)(2)(A) states that the term “related per-
son” “include[s]” a successor in interest of “any person de-
scribed in clause (i), (ii), or (iii),” and because these clauses
mention the “signatory operator” itself, the signatory opera-
tor is “described” in clause (i) by virtue of the express refer-
ence. Brief for Petitioner 24.
The text of the statute does not support this reading.
Where Congress wanted to include successors in interest, it
did so clearly and explicitly. See supra, at 452–453. Each
category of “related persons” describes a definitive group of
persons. § 9701(c)(2). Congress neither created a separate
category for signatory operators nor included signatory op-
erators within these categories. It is unlikely that Congress
intended to attach liability to a group such as successors in
interest to signatory operators through a general clause that
was meant to reach persons “described” in one of three ex-
plicit categories.
Second, the Commissioner argues that, under § 9701(c)(2)
(A)(i), a signatory operator is necessarily a member of a con-
trolled group of corporations that includes itself. Brief for
Petitioner 24. This subsection provides that “related per-
sons” include “a member of the controlled group of corpora-
tions (within the meaning of section 52(a)) which includes
such signatory operator.” § 9701(c)(2)(A)(i). Thus, accord-
ing to the Commissioner’s logic, if corporation A is a member
of a controlled group that includes corporations A, B, and C,
then a “successor in interest” of a member of the group of
corporations A, B, and C includes a successor in interest of
corporation A. Ibid.
Standing alone, the subsection supports the Commission-
er’s argument that a signatory operator is necessarily a
member of a group of corporations that includes itself. But
this provision cannot be divorced from the clause that begins

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456 BARNHART v. SIGMON COAL CO.
Opinion of the Court
the related persons provision: “A person shall be considered
to be a related person to a signatory operator if that person
is—.” § 9701(c)(2)(A) (emphasis added). Under the Com-
missioner’s reading, the signatory operator would be related
to itself. But just as it makes little sense to say that I am
a related person to myself, it makes little sense to say that a
signatory operator is a related person to itself. The statute
therefore necessarily implies that a “related person” is a sep-
arate entity from a signatory operator. Moreover, the Com-
missioner’s argument only works where the signatory opera-
tor is actually part of a “controlled group of corporations.”
The Commissioner does not account for the situation where
a signatory operator is not part of a controlled group. And
because the Commissioner does not contend that Shackleford
was part of such a controlled group of corporations, this ar-
gument, in any event, has no force here.
B
The Commissioner also contends that the background, leg-
islative history, and purposes of the Coal Act confirm that
Congress intended that liability for a signatory operator’s
employees could be placed on the signatory’s direct successor
in interest.
1
As support, the Commissioner turns to the floor state-
ments of Senators Malcolm Wallop and Jay Rockefeller, ar-
guing that, because these Senators sponsored the Coal Act,
their views are entitled to special weight. In particular, the
Commissioner relies on an explanation of the legislation
placed into the record by Senator Wallop, making the point
that, in addition to the three categories of related persons,
“the statute provides that related persons” includes “(iv)
in specific instances successors to the collective bargaining
agreement obligations of a signatory operator.” 138 Cong.

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Opinion of the Court
Rec. 34002 (1992).13 The Commissioner also points to Sena-
tor Rockefeller’s statement that “[t]he term ‘signatory opera-
tor,’ as defined in new section 9701(c)(1), includes a successor
in interest of such operator.” Id., at 34033.14
Floor statements from two Senators cannot amend the
clear and unambiguous language of a statute. We see no
reason to give greater weight to the views of two Senators
than to the collective votes of both Houses, which are memo-
rialized in the unambiguous statutory text.15
13 Placed in its proper context, this statement is entirely consistent with
the statutory text. Senator Wallop noted first that the bill makes “each
such related person fully responsible for the signatory operator’s obliga-
tion to provide benefits under the Act should the signatory no longer be
in business, or otherwise fail to fulfill its obligations under the Act.” 138
Cong. Rec., at 34002 (emphasis added). After listing the three categories
of related persons, Senator Wallop then added category (iv): “in specific
instances successors to the collective bargaining agreement obligations of
a signatory operator—are equally obligated with the signatory operator
to pay for continuing health care coverage.” Ibid. (emphasis added). To
begin with, it must be noted that Senator Wallop did not state that all
successors are responsible for the beneficiaries. Rather, he narrowed the
group with the qualifying phrase “in specific instances.” And Senator
Wallop did not suggest that responsibility attaches to successors in inter-
est to signatory operators. Instead, the “successors to the collective bar-
gaining agreement obligations” are nothing more than those entities that
he previously identifies as “fully responsible for the signatory operator’s
obligation”: the related persons categorized in clauses (i)–(iii). Conse-
quently, the statement is consistent with the final sentence of the related
persons definition which provides that “[a] related person shall also include
a successor in interest of any person described in clause (i), (ii), or (iii).”
§ 9701(c)(2)(A).
14 We need look to only the statutory text to know that the definition in
fact does not include the successor in interest. See § 9701(c)(1) (“The
term ‘signatory operator’ means a person which is or was a signatory to
a coal wage agreement”). See supra, at 455.
15 Despite the dissent’s assertion that we should defer to what it charac-
terizes as “clear evidence of coherent congressional intent,” post, at 462
(opinion of Stevens, J.), the dissent points to only two sentences in the
Congressional Record. Even if we were to believe that floor statements

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458 BARNHART v. SIGMON COAL CO.
Opinion of the Court
2
The Commissioner also argues that construing the related
person provision to exclude a signatory’s direct successor in
interest would be contrary to Congress’ stated purpose of
ensuring that each Combined Fund beneficiary’s health care
costs is borne (if possible) by the person with the most direct
responsibility for the beneficiary, not by persons that had no
connection with the beneficiary or by the public fisc. The
Commissioner contends that the Court should choose a con-
struction of the statute that effectuates Congress’ “overrid-
ing purpose” of avoiding a recurrence of the orphan retiree
catastrophe, which was caused in large part by operators
avoiding responsibility for their beneficiaries by changing
their corporate structures, selling assets, or ceasing opera-
tions. See Brief for Petitioner 30.
can amend clear statutory language, these statements can hardly be char-
acterized as “clear evidence.” To begin with, the dissent mischaracter-
izes Senator Wallop’s statement, neglecting to explain its context and to
include the qualifying phrase “in specific instances.” See supra, at 457,
n. 13. Absent support from Senator Wallop’s statement, the dissent is
left only with Senator Rockefeller’s explanation. The dissent essentially
contends that we should use a single sentence in a long colloquy to effect
a major change in the statute. However, the dissent fails to note that
the House passed the bill on October 5, 1992, three days before Senator
Rockefeller made his statement. See 6 Legislative History of the Energy
Policy Act of 1992 (Committee Print compiled for the Senate Committee
on Energy and Natural Resources by the Library of Congress), p. 4678
(1994) (hereinafter Legislative History). There is no indication that Sen-
ator Rockefeller’s version of the provision garnered the support of the
House, the Senate, and the President. And, given that the House had
already passed the bill, the dissent’s additional reliance on the absence of
a response to the Senators’ explanation simply makes no sense. See post,
at 468–469. Moreover, were we to adopt this form of statutory interpre-
tation, we would be placing an obligation on Members of Congress not
only to monitor their colleague’s floor statements but to read every word
of the Congressional Record including written explanations inserted into
the record. This we will not do. The only “evidence” that we need rely
on is the clear statutory text.

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Opinion of the Court
The Commissioner further suggests that the Court of
Appeals’ construction of the statute leads to the counter-
intuitive result that a direct successor in interest of a
signatory may not be made responsible for a signatory’s
beneficiaries—even though such successor liability would be
supported by the background principles of successorship 16 —
while a more distantly related successor in interest of a cor-
porate affiliate of a signatory operator may be made respon-
sible for the signatory’s beneficiaries. Thus, the Commis-
sioner appears to request that the Court invoke some form
of an absurd results test. Id., at 32 (citing United States v.
X-Citement Video, Inc., 513 U. S. 64, 70–71 (1994); United
States v. Brown, 333 U. S. 18, 27 (1948)).17
Respondents correctly note that the Court rarely invokes
such a test to override unambiguous legislation. Moreover,
respondents offer several explanations for why Congress
would have purposefully exempted successors in interest of
a signatory operator from the “related person” definition.
16 The Commissioner asks that the Court apply the background princi-
ples of successorship, as articulated in the Court’s treatment of labor, em-
ployment, and benefit statutes, that a corporate entity’s liability under a
statutory scheme should be attributed to the entity’s direct successor in
interest. Brief for Petitioner 36–40. But in the Coal Act, Congress ex-
pressly delineated those parties to which it sought to attach responsibility.
Where a statute provides an explicit and all-inclusive scheme that does
not include successors in interest to signatory operators, and where there
is no indication that Congress intended that the statute be supplemented
by reference to background principles, we will not import these principles
into our analysis.
17 The dissent makes the conclusory assertion that our “interpretation
of the statute . . . recreates the same difficulties that beset the NBCWAs
and that Congress explicitly sought to avoid.” See post, at 471. The dis-
sent, however, provides no data for its conclusory assertion. Nor does it
explain how our interpretation “recreates the same difficulties that beset
the NBCWAs.” Ibid. And the dissent ignores the fact that the new
scheme broadly expanded the group of persons responsible for beneficiar-
ies. Thus, the fact that Congress declined to attach liability to one group
of persons tells us nothing about the new system’s viability.

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460 BARNHART v. SIGMON COAL CO.
Opinion of the Court
First, respondents argue that coal operators undoubtedly
would have opposed legislation that seriously expanded their
liability with respect to miners that they had never em-
ployed,18 and that it is hard to imagine that the 1988 signa-
tory companies would have agreed to a compromise that
exposed them to open-ended statutory liability linked to
decades of buying, selling, and trading property. Brief for
Respondents 39–43.
Second, respondents speculate that Congress may have
concluded that injecting coal industry successor issues into
the Commissioner’s task of allocating liability for more than
100,000 UMWA retirees and dependents would consume a
disproportionate share of the agency’s resources, create grid-
lock in the assignment process, precipitate endless operator
challenges under the Coal Act’s administrative review proc-
ess, and thwart implementation of the program. Id., at 43–
45. Finally, respondents suggest that Congress could have
been concerned about the adverse impact that successor lia-
bility might have had on the valuation and sale of union com-
panies and properties.19 Id., at 45–46.
Where the statutory language is clear and unambiguous,
we need neither accept nor reject a particular “plausible”
explanation for why Congress would have written a statute
18 Respondents argue that successor liability covering 40 years of pre-
Act transactions could have exploded the number of Combined Fund bene-
ficiaries potentially assignable to the 1988 signatory operators. See Brief
for Respondents 41. It would have been difficult for the 1988 signatories
to estimate their potential liability under a legislative fix that included
successor liability. Thousands of pre-1976 UMWA retirees were potential
candidates for assignment to a 1988 NBCWA signatory under such broad
based successor liability.
19 If Congress had retroactively burdened coal asset purchasers for
financial shortfalls arising from failures under a private party contract,
respondents argue, future purchasers would be wary about paying fair
market value for coal property. Such concerns might destabilize the un-
ionized industry’s economic underpinning, at a time when many assigned
operators might need to raise money to help defray costs imposed by
the Act.

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Opinion of the Court
that imposes liability on the successors of the companies that
fall within the categories of §§ 9701(c)(2)(A)(i)–(iii) but not on
successors to the signatory operators themselves. Dissatis-
fied with the text of the statute, the Commissioner attempts
to search for and apply an overarching legislative purpose to
each section of the statute. Dissatisfaction, however, is
often the cost of legislative compromise. And negotiations
surrounding enactment of this bill tell a typical story of legis-
lative battle among interest groups, Congress, and the Presi-
dent. See supra, at 445–446, and nn. 6–7. Indeed, this
legislation failed to ease tensions among many of the inter-
ested parties.20 Its delicate crafting reflected a compromise
amidst highly interested parties attempting to pull the pro-
visions in different directions. See, e. g., 6 Legislative His-
tory 4569–4571. As such, a change in any individual provi-
sion could have unraveled the whole. It is quite possible
that a bill that assigned liability to successors of signatory
operators would not have survived the legislative process.
The deals brokered during a Committee markup, on the floor
of the two Houses, during a joint House and Senate Confer-
ence, or in negotiations with the President, however, are not
for us to judge or second-guess.
Our role is to interpret the language of the statute enacted
by Congress. This statute does not contain conflicting pro-
visions or ambiguous language. Nor does it require a nar-
rowing construction or application of any other canon or
interpretative tool. “We have stated time and again that
courts must presume that a legislature says in a statute what
20 The UMWA’s lobbying efforts precipitated a lawsuit by the Pittston
Coal Company, which sued the UMWA for $250 million, alleging “that at
the conclusion of the 1989–1990 strike, the union promised not to lobby on
behalf of legislation making ‘reachback’ companies resume payments to
the” retiree health system. UMW Denies Breaching Pittston Pact, 17
Coal Outlook, Dec. 6, 1993, 1993 WL 2678868. “Pittston accused the union
of violating a promise not to lobby for industry wide taxation to bail out
two retiree health funds.” UMW, Pittston Reach Tentative Deal, 18 Coal
Outlook, June 20, 1994, 1994 WL 2480375.

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462 BARNHART v. SIGMON COAL CO.
Stevens, J., dissenting
it means and means in a statute what it says there. When
the words of a statute are unambiguous, then, this first canon
is also the last: ‘judicial inquiry is complete.’ ” Connecticut
Nat. Bank v. Germain, 503 U. S. 249, 253–254 (1992) (quoting
Rubin v. United States, 449 U. S. 424, 430 (1981)) (citations
omitted). We will not alter the text in order to satisfy the
policy preferences of the Commissioner. These are battles
that should be fought among the political branches and the
industry. Those parties should not seek to amend the stat-
ute by appeal to the Judicial Branch.
C
The Commissioner’s final argument is that, even if the
Coal Act did not affirmatively provide that responsibility for
combined fund premiums may be imposed on a signatory’s
direct successor, it was reasonable for the Commissioner
to conclude that direct successors of a signatory operator
should be responsible for the operator’s employees. Con-
gress, however, did not delegate authority to the Commis-
sioner to develop new guidelines or to assign liability in a
manner inconsistent with the statute. In the context of an
unambiguous statute, we need not contemplate deferring to
the agency’s interpretation. See Chevron U. S. A. Inc. v.
Natural Resources Defense Council, Inc., 467 U. S. 837, 842–
843 (1984).
Accordingly, the judgment of the Court of Appeals is
affirmed.
It is so ordered.
Justice Stevens, with whom Justice O’Connor and
Justice Breyer join, dissenting.
This case raises the question whether clear evidence of
coherent congressional intent should inform the Court’s con-
struction of a statutory provision that seems, at first blush,
to convey an incoherent message. Today, a majority of the
Court chooses to disregard that evidence and, instead, ad-

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463 Cite as: 534 U. S. 438 (2002)
Stevens, J., dissenting
heres to an interpretation of the statute that produces ab-
surd results. Two Members of Congress—both sponsors of
the legislation at issue—have explained that the statute does
not mandate such results, and the agency charged with ad-
ministering the statute agrees. As a partner of the other
two branches of Government, we should heed their more rea-
sonable interpretation of Congress’ objectives.
The Coal Industry Retiree Health Benefit Act of 1992
(Coal Act or Act), 26 U. S. C. § 9701 et seq. (1994 ed. and Supp.
V), authorizes the Commissioner of Social Security (Commis-
sioner) to assign responsibility for providing health care ben-
efits for certain retired coal miners and their beneficiaries.
It was enacted in response to the financial difficulties that
had plagued the National Bituminous Coal Wage Agree-
ments (NBCWAs), a multiemployer, private health care
system, established by representatives of the coal industry
and the United Mine Workers Association (UMWA). See
Eastern Enterprises v. Apfel, 524 U. S. 498, 511 (1998). The
NBCWAs were part of an arrangement in which the UMWA
accepted collective-bargaining agreements dictating wages,
benefits, and other terms of employment in exchange for,
inter alia, promises regarding the provision of lifetime
health benefits for retired miners. After many of the coal
operators who were signatories to the NBCWAs went out
of business or withdrew from their coverage, the remaining
signatories were forced to assume a share of the health care
costs for those operators’ employees.
Consequently, the remaining members had an even greater
incentive to avoid their obligations under the agree-
ments. Ibid. The ensuing downward spiral threatened the
NBCWAs’ ability to provide health benefits. In evaluating
legislative solutions, Congress “was advised that more than
120,000 retirees might not receive ‘the benefits they were
promised’ ” during the collective-bargaining process. Id., at
513 (quoting Coal Commission Report on Health Benefits of
Retired Coal Miners: Hearing before the Subcommittee on

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464 BARNHART v. SIGMON COAL CO.
Stevens, J., dissenting
Medicare and Long-Term Care of the Senate Committee on
Finance, 102d Cong., 1st Sess., 45 (1991) (statement of Bitu-
minous Coal Operator’s Association Chairman Michael K.
Reilly)). Congress’ objective in passing the Coal Act was to
“identify persons most responsible for plan liabilities” and to
establish an order of priority to ensure the long-term viabil-
ity of the fund. Energy Policy Act of 1992, Pub. L. 102–486,
§ 19142, 106 Stat. 3037.
To accomplish that goal, the Act directs the Commissioner
to assign primary responsibility to a “signatory operator”
that formerly employed the particular miners and to persons
“related” to that operator. The broad definition of the term
“related person” includes three classes of entities associated
with the signatory and a catchall sentence stating that a “re-
lated person shall also include a successor in interest of any
person described in clause (i), (ii), or (iii).” 1 The question
in this case is whether the Act permits the Commissioner to
assign retirees to a successor of the signatory itself, or just
successors of related persons of the signatory.
The Commissioner reads the statute broadly to include di-
rect successors, whereas the Court has adopted a narrower
reading that excludes them from responsibility. Because a
signatory operator is not “described in” clause (i), (ii), or (iii),
1 Title 26 U. S. C. § 9701(c)(2)(A) (1994 ed.) provides: “A person shall be
considered to be a related person to a signatory operator if that person
is—
“(i) a member of the controlled group of corporations (within the mean-
ing of [26 U. S. C. § ]52(a)) which includes such signatory operator;
“(ii) a trade or business which is under common control (as determined
under [26 U. S. C. § ]52(b)) with such signatory operator; or
“(iii) any other person who is identified as having a partnership interest
or joint venture with a signatory operator in a business within the coal
industry, but only if such business employed eligible beneficiaries, except
that this clause shall not apply to a person whose only interest is as a
limited partner.
“A related person shall also include a successor in interest of any person
described in clause (i), (ii), or (iii).”

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465 Cite as: 534 U. S. 438 (2002)
Stevens, J., dissenting
the Court concludes that a successor in interest to a signa-
tory cannot be liable for the retirees of its predecessor under
the catchall provision. Thus, the Court reads the Act to as-
sign liability first to the signatory operator, assuming it is
still in business, then to any related persons of that signa-
tory, and if none exists or is still in business, to the successor
in interest of a related person. Liability can never be as-
signed to a direct successor—the most logical recipient of
liability, after the signatory itself.
Two examples illustrate the absurdity of the Court’s read-
ing. First, imagine that corporations “A” and “B” operate
coal mines in Kentucky and Illinois, respectively. A and B
are affiliated corporations; let us say they are members of
the same controlled group of corporations. In 1974, each
company became a signatory to one of the coal agreements.
Subsequently, they both sell their assets to separate purchas-
ers. Under the Court’s reading of the Act, the purchaser of
the Kentucky mines would be responsible for the health care
costs of the Illinois miners and the purchaser of the Illinois
mines would be assigned the retirees of the Kentucky com-
pany, but neither purchaser would be liable for its predeces-
sor’s retired employees.
Now, consider a slightly different scenario in which A still
operates a coal mine, but B runs a dairy farm. They are
still members of the same controlled group of corporations,
however, only A is a signatory of the 1974 agreement. In
this hypothetical, when A and B sell their assets, under the
Court’s reading of the statute, the purchaser of the dairy
farm will be liable for the retired miners’ benefits while the
purchaser of the coal mine has no liability. If that result is
not absurd, it is surely incoherent. Why would Congress
order such an odd result?
The answer is simple—Congress did not intend this result.
Commenting on the final text of the bill that was ultimately
enacted, two of the Senators sponsoring the measure ex-
plained their understanding of the statutory text to their col-

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466 BARNHART v. SIGMON COAL CO.
Stevens, J., dissenting
leagues. Senator Rockefeller of West Virginia, who spoke
“as the original author of this legislation,” 138 Cong. Rec.
34034 (1992), unambiguously stated that the term “signatory
operator” includes “a successor in interest of such operator.”
Id., at 34033. And in a written explanation of the measure
that he placed in the Congressional Record, Senator Wallop
stated that the definition of the term “related person” was
“intentionally very broad” and encompassed “successors to
the collective bargaining agreement obligations of a signa-
tory operator.” 2
2 It is of particular interest that he did not limit the scope of potential
assignees to those in the three subparagraphs of § 9701(c)(2)(A). He
stated:
“[B]ecause of complex corporate structures which are often found in the
coal industry, the number of entities made jointly and severally liable for
a signatory operator’s obligations under the definition of related persons
is intentionally very broad.
“In this regard, the term ‘related person’ is defined broadly to include
companies related to the signatory operator. The Conference Agreement
makes each such related person fully responsible for the signatory opera-
tor’s obligation to provide benefits under the Act should the signatory no
longer be in business, or otherwise fail to fulfill its obligations under the
Act. Thus, the statute provides that related persons—meaning (i) those
within the controlled group of corporations including the signatory opera-
tor, using a 50% common ownership test, (ii) a trade or business under
common control with a signatory operator, (iii) one with a partnership
interest or joint venture with the signatory operator, or (iv) in specific
instances successors to the collective bargaining agreement obligations
of a signatory operator—are equally obligated with the signatory opera-
tor to pay for continuing health care coverage.” 138 Cong. Rec. 34002
(1992) (emphasis added).
The meaning of Senator Wallop’s reference to “specific instances” is not
evident, but he surely did not mean “no instances” as the Court seems to
assume. See ante, at 457, n. 13. Nor could the phrase “successors to the
collective bargaining agreement obligations of a signatory operator” refer
to the successors of persons described in clauses (i)–(iii), because members
of the same controlled group of corporations, for example, do not assume
each other’s collective-bargaining agreement obligations. In specific in-
stances, however, direct successors of signatory operators may assume
those obligations. See infra, at 467–468.

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467 Cite as: 534 U. S. 438 (2002)
Stevens, J., dissenting
If we assume that Senators Rockefeller and Wallop cor-
rectly understood their work product, the provision is coher-
ent. For it is obviously sensible to impose the cost of health
care benefits on successors to signatory operators, and
equally obvious that there is far less justification for impos-
ing such liability on successors to related companies that are
not engaged in coal mining. Moreover, assigning liability to
direct successors is consistent with Congress’ explicit objec-
tive to “identify persons most responsible for plan liabili-
ties.” § 19142(a)(2), 106 Stat. 3037.3 As between the two,
the successor to a signatory has more notice that it may be
held responsible for its predecessor’s liabilities than the suc-
cessor of a related person of the signatory. In fact, succes-
sors to signatories of the 1974 NBCWA are specifically on
notice because of a provision in that agreement which states:
“[The] Employer promise[s] that its operations covered by
this Agreement shall not be sold, conveyed, or otherwise
transferred or assigned to any successor without first secur-
ing the agreement of the successor to assume the Employer’s
obligations under this Agreement.” Article I, National Bi-
tuminous Coal Wage Agreement of 1974.
Not only is the direct successor put on notice; presumably
it received a lower sale price in exchange for assuming the
collective-bargaining agreement obligations of its predeces-
sor. Consider the facts of this case. Respondent, Jericol
Mining, Inc., purchased the coal mining assets of Shackleford
Coal Co., a signatory to the 1971 NBCWA. The sales con-
3 Senator Wallop emphasized this point in clarifying why liability under
§ 9701(c) is “intentionally very broad.” 138 Cong. Rec., at 34002. As he
explained: “The purpose of this provision is to insure that every reason-
able effort is made to locate a responsible party to provide the benefits
before the cost is passed to other signatory companies which have never
had any connection to the individual . . . . Allocation of beneficiaries to
an entity or business which continues in business is the basic statutory
intent. Thus, the Conference Agreement’s overriding purpose is to find
and designate a specific obligor for as many beneficiaries in the Plans as
possible.” Ibid.

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468 BARNHART v. SIGMON COAL CO.
Stevens, J., dissenting
tract provided that Jericol would assume responsibility for
Shackleford’s outstanding contracts, including its collective-
bargaining agreement. App. 23, 26. The price Jericol paid
for Shackleford’s assets, therefore, must have reflected the
fact that Jericol was taking on Shackleford’s commitments to
its retirees. By allowing Jericol to escape responsibility for
its end of the bargain at this stage, the Court effectively
grants it a windfall.
While the Court trumpets the clear language of the stat-
ute, the language here is not clear enough to require disre-
gard of “clearly expressed legislative intention to the con-
trary,” Consumer Product Safety Comm’n v. GTE Sylvania,
Inc., 447 U. S. 102, 108 (1980), or to require us to accept “ab-
surd results,” United States v. Turkette, 452 U. S. 576, 580
(1981) (citing Trans Alaska Pipeline Rate Cases, 436 U. S.
631, 643 (1978)). See infra, at 469–470. Nevertheless, the
Court accepts respondents’ claim that, even if the statute
produces odd results, this scheme is the product of a legisla-
tive compromise that we cannot override. The drafters, ac-
cording to this theory, may have confronted significant oppo-
sition from successors of signatories who would have faced
liability under alternative language. Or Congress may have
been concerned that imposing liability on successors would
create a disincentive for potential purchasers of coal compa-
nies’ assets.
If the negotiations were as contentious as respondents
imagine and if the Act excluded direct successors as the
product of horsetrading, then one would expect a response
to the statements of two Senators directly contradicting the
terms of that legislative bargain. Surely those Senators
who disagreed with Senators Rockefeller and Wallop would
have said something to set the record straight. To the con-
trary, there is no evidence in the legislative history of such
a compromise. Respondents and amici do not cite any evi-
dence supporting this version of events, nor could respond-

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469 Cite as: 534 U. S. 438 (2002)
Stevens, J., dissenting
ents’ counsel when asked specifically during oral argument.
Tr. of Oral Arg. 33–35.
The total absence of any suggestion in the legislative
history that the Senators had misdescribed the coverage of
the Act is itself significant. See Harrison v. PPG Indus-
tries, Inc., 446 U. S. 578, 602 (1980) (Rehnquist, J., dissent-
ing) (“In a case where the construction of legislative lan-
guage . . . makes so sweeping and so relatively unorthodox
a change . . . , I think judges as well as detectives may take
into consideration the fact that a watchdog did not bark in
the night”); Green v. Bock Laundry Machine Co., 490 U. S.
504, 527 (1989) (Scalia, J., concurring in judgment) (when
confronted with statutory language that produces an absurd
result, it is appropriate “to observe that counsel have not
provided, nor have we discovered, a shred of evidence that
anyone has ever proposed or assumed such a bizarre disposi-
tion”). Absent some response indicating that the Senators
mischaracterized the Act, we ought to construe the statute
in light of its clear purpose and thereby avoid the absurd
results that the majority countenances.
Indeed, the Court’s cavalier treatment of the explanations
of the statute provided to their colleagues by Senators
Rockefeller and Wallop is disrespectful, not only to those
Senators, but to the entire Senate as well. For, although
the Court does not say so explicitly, it apparently assumes
that the Senators were either dissembling or unable to un-
derstand the meaning of the bill that they were sponsoring.
Neither assumption is tenable. Much more likely is the sim-
ple explanation that the Senators quite reasonably thought
the term “signatory operator” included successors. This ac-
count is certainly consistent with Congress’ instructions in
the Dictionary Act, 1 U. S. C. § 1, that a reference to a corpo-
ration may embrace its successors and assigns even if not
expressly mentioned.
The Coal Act defines a “signatory operator” as “a person
which is or was a signatory to a coal wage agreement.” 26

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470 BARNHART v. SIGMON COAL CO.
Stevens, J., dissenting
U. S. C. § 9701(c)(1) (1994 ed.). The term “person” is not de-
fined, but according to the Dictionary Act it includes “corpo-
rations, companies, associations, firms, partnerships, socie-
ties, and joint stock companies, as well as individuals.” 1
U. S. C. § 1. And, we know from 1 U. S. C. § 5 that “[t]he
word ‘company’ or ‘association’, when used in reference to a
corporation, shall be deemed to embrace the words ‘succes-
sors and assigns of such company or association’, in like man-
ner as if these last-named words, or words of similar import,
were expressed.” Therefore, reading the term “signatory
operator” to encompass direct successors is compatible with
the default rules that Congress provided for interpreting its
statutes. Nor does the context indicate otherwise, because
Congress clearly authorized the Commissioner to assign re-
tirees to other successors, and extending liability to this cat-
egory of successors is consistent with the purpose of the Act.
Cf. Rowland v. California Men’s Colony, Unit II Men’s Ad-
visory Council, 506 U. S. 194, 209–211 (1993) (recognizing
that even when “contextual features” contradict the Diction-
ary Act reading, that interpretation may be appropriate if it
would make little sense to adopt a more literal reading); Wil-
son v. Omaha Tribe, 442 U. S. 653, 666 (1979); United States
v. A & P Trucking Co., 358 U. S. 121, 123–124 (1958).
Three additional considerations support reading the Act to
cover direct successors. First, this reading was consistently
endorsed by the several Commissioners responsible for the
administration of the Act, notwithstanding a change in con-
trol of the Executive Branch.4 We have previously attached
4 Although the Social Security Administration has interpreted the mean-
ing of “successor” differently over time (i. e., taking different positions as
to whether an asset purchaser qualifies as a successor), it has consistently
taken the position that a direct successor can be assigned responsibility
for a signatory’s employees. See Provisions Relating to the Health Bene-
fits of Retired Coal Miners: Hearing before the House Committee on Ways
and Means, 103d Cong., 1st Sess., 24–25 (1993) (statement of then-Acting
Commissioner Lawrence H. Thompson) (explaining that miners can be

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471 Cite as: 534 U. S. 438 (2002)
Stevens, J., dissenting
significance to the fact that after “a new administration took
office” an agency concluded that a statutory “term should be
given the same definition” as before. Chevron U. S. A. Inc.
v. Natural Resources Defense Council, Inc., 467 U. S. 837,
857–858 (1984).
Second, it is consistent with the Court’s treatment of
successorship issues in other labor cases, in which we have
required successors to bargain with a union certified under
a predecessor, see Fall River Dyeing & Finishing Corp. v.
NLRB, 482 U. S. 27, 41 (1987), to assume liability for re-
instatement and backpay as a result of a predecessor’s unfair
labor practice, see Golden State Bottling Co. v. NLRB, 414
U. S. 168, 181–185 (1973), and to arbitrate disputes as pro-
vided in a predecessor’s collective-bargaining agreement, see
John Wiley & Sons, Inc. v. Livingston, 376 U. S. 543, 548
(1964).
Finally, we should avoid adopting an interpretation of the
statute that recreates the same difficulties that beset the
NBCWAs and that Congress explicitly sought to avoid. The
immediate consequence of the Court’s reading is that 86 re-
tired miners will now be unassigned; therefore, their health
care expenses will be borne by the remaining signatory oper-
ators and their related persons. Assuming there are other
retired miners in the same category, today’s decision will re-
sult in more “orphaned” miners who will draw from the com-
bined fund. To the extent that the cost for their health ben-
efits will be passed along to the other signatory operators,
the Court’s holding creates an added incentive for the re-
assigned to “the last active signatory operator (or its successor, if the
operator is out of business) for whom the miner worked”); Letter to SSA
Southeastern Program Service Center (Aug. 8, 1994), App. 110–111
(“[S]uccessors or successors in interest are treated for assignment pur-
poses as if there had been no change of ownership”); Supplemental Coal
Act Review Instructions No. 4 (July 1995), App. to Pet. for Cert. 86a
(“[T]he Coal Act does permit assignments to ‘successors’ and ‘successors-
in-interest’ to defunct (inactive) signatory operators”).

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472 BARNHART v. SIGMON COAL CO.
Stevens, J., dissenting
maining signatories to avoid their obligations under the
agreements. The result is effectively the same downward
spiral that doomed the NBCWAs.5 Eastern, 524 U. S., at
511.
In my judgment the holding in this case is the product of
a misguided approach to issues of statutory construction.
The text of the statute provides us with evidence that is
usually sufficient to disclose the intent of the enacting Con-
gress, but that is not always the case. There are occasions
when an exclusive focus on text seems to convey an incoher-
ent message, but other reliable evidence clarifies the statute
and avoids the apparent incoherence. In such a case—and
this is one—we should never permit a narrow focus on text
to obscure a commonsense appraisal of that additional
evidence.
I respectfully dissent.
5 For the first three years of the Act, the health care costs for orphaned
miners are shared among the signatories. Starting in the fourth year,
payment is deducted first from interest earned on the Department of Inte-
rior’s Abandoned Mine Reclamation Fund (AML), 26 U. S. C. § 9705(b)
(1994 ed.). If those funds are exhausted or unavailable, then the costs are
shared by the remaining signatories. While the availability of the inter-
est transfers may delay another financial crisis, it should be noted that the
AML funds are earmarked for other purposes. See 30 U. S. C. § 1232(g)
(1994 ed.); CRS Report, Coal Industry: Use of Abandoned Mine Reclama-
tion Fund Monies for UMWA “Orphan Retiree” Health Benefits, 138 Cong.
Rec. 34004, 34006 (1992) (“First priority goes to mining abandonments that
could present imminent danger to public health and safety. . . . Any re-
maining AML funds are designated to eliminate environmental hazards”).
Moreover, given the high cost of health care for retired miners, and the
likely diminution of the fund’s interest earning capacity, see id., at 34006–
34007, the interest may not last for long.