barnhart commissioner social security sigmon coal et argued november decided february coal industry retiree health benefit act coal act act restructured system providing private health care benefits coal industry retirees act merged benefit plans created pursuant agreements mine workers america umwa coal operators new multiemployer plan called umwa combined benefit fund combined fund see fund financed annual premiums assessed signatory coal operators signed agreement requiring contributions benefits plans signatory longer business act assigns liability beneficiaries defined group related persons see act charges commissioner social security assigning eligible beneficiary signatory operator related persons identifies specific categories signatory operators related persons requires commissioner assign beneficiaries among categories particular order ibid ensures beneficiary remains unassigned existing company falls within categories benefits financed combined fund see shortly respondent jericol mining jericol formed irdell mining irdell another company purchased coal mining operating assets shackleford coal signatory coal wage agreement business among things assumed responsibility shackleford agreement umwa common ownership irdell shackleford irdell subsequently changed name operating shackleford coal changed name jericol commissioner assigned premium responsibility retired miners jericol determining successor successor interest original shackleford jericol qualified related person shackleford retirees worked shackleford none actually worked jericol jericol respondent sigmon coal company person related jericol filed suit commissioner district granted summary judgment concluding act classification regime provide liability successors defunct signatory operators affirming fourth circuit concluded act clear unambiguous bound read exactly written held inter alia jericol related person shackleford thus held responsible shackleford miners held coal act permit commissioner assign retired miners successors interest signatory operators pp act explicit may assigned liability beneficiaries neither related persons provision provision successors interest signatory operators may assigned liability act plain language necessarily precludes commissioner assigning disputed miners jericol statutory language unambiguous inquiry ceases see ron pair enterprises since retirees issue shackelford employees signatory operator sold assets jericol commissioner assign beneficiaries jericol related person shackleford section person shall considered related person signatory operator person member controlled group corporations includes signatory operator ii trade business common control signatory operator iii person partnership interest joint venture signatory operator exceptions related person also includes successor interest person described clause ii iii contention jericol ever member controlled group corporations including shackleford ever business common control shackleford ever partnership interest engaged joint venture ford therefore liability beneficiaries may attach jericol successor interest entity described iii jericol successor interest shackleford jericol liable signatory operator shackleford falls within one categories none three categories however includes signatory operator inclusion inferred since general principle statutory construction one statutory section includes particular language omitted another section act presumed congress acted intentionally purposely russello congress wanted provide successor liability coal act explicitly demonstrated congress meant make preenactment successor interest like jericol liable done clearly explicitly pp rejects commissioner arguments light coal act text structure purposes direct successor interest entity signatory operator included within liability scheme responsible operator combined fund premiums operator defunct related person still business pp act text supports neither two readings proposed commissioner first commissioner argues last sentence related person include successor interest person described clause ii iii clauses mention signatory operator operator described clause virtue express reference unlikely congress neither created separate category signatory operators included signatory operators within categories intended attach liability group successors interest signatory operators general clause meant reach persons described one three explicit categories second commissioner argues signatory operator necessarily member controlled group corporations includes successor interest member group includes successor interest signatory operator section however divorced clause begins related persons provision person shall considered related person signatory operator person emphasis added makes little sense signatory operator related statute necessarily implies related person separate entity signatory operator moreover commissioner argument works signatory operator actually part controlled group corporations argument force event commissioner contend shackleford part group pp floor statements two senators sponsored coal act commissioner alleges support position amend unambiguous language statute reason give greater weight senator floor statement collective votes houses memorialized unambiguous statutory text pp also unavailing commissioner argument construing related person provision exclude signatory direct successor interest contrary congress stated purposes ensuring combined fund beneficiary health care costs borne possible person direct responsibility beneficiary persons connection beneficiary public fisc commissioner appears request application form absurd results test respondents answer correctly rarely invokes test override unambiguous legislation offer several explanations congress purposefully exempted successors interest signatory operator related person definition statutory language clear unambiguous need neither accept reject particular plausible explanation congress written statute negotiations surrounding bill enactment tell typical story legislative battle among interest groups congress president quite possible bill assigned liability successors signatory operators survived legislative process deals brokered committee floor two houses joint house senate conference negotiations president whose role interpret language statute enacted congress alter unambiguous text order satisfy commissioner policy preferences pp finally rejects commissioner suggestion reasonable conclude direct successors signatory operator responsible operator employees interpretation entitled deference context unambiguous statute need contemplate deferring agency interpretation see chevron natural resources defense council affirmed thomas delivered opinion rehnquist scalia kennedy souter ginsburg joined stevens filed dissenting opinion breyer joined jo anne barnhart commissioner social security petitioner sigmon coal company et al writ certiorari appeals fourth circuit february justice thomas delivered opinion case arises commissioner social security assignment pursuant coal industry retiree health benefit act coal act act et seq ed supp retired coal miners jericol mining company jericol question presented whether coal act permits commissioner assign retired miners successors interest signatory appeals fourth circuit held sigmon coal apfel affirm coal act reconfigured system providing private health care benefits retirees coal industry restructuring system congress contend half century agreements coal industry mine workers america umwa coal miners union tensions coal operators umwa often led lengthy strikes serious economic consequences industry employees confronted industry fraught contention congress faced difficult first time federal government called intervene negotiations within industry tensions motivated president truman issue executive order directing secretary interior take possession bituminous coal mines negotiate umwa changes terms conditions miners employment see eastern enterprises apfel plurality opinion quoting fed reg negotiations culminated first many agreements resulted creation benefit funds compensating miners dependents survivors subsequently umwa several coal operators entered collectively bargained agreement national bituminous coal wage agreement nbcwa established fund three trustees given authority determine among things allocation benefits miners families disagreement prompted parties negotiate another nbcwa following year bituminous coal operators association bcoa created multiemployer bargaining association primary representative coal operators negotiations umwa nbcwa amended occasionally new nbcwas adopted terms structure agreement remained largely unchanged ibid order comply employee retirement income security act erisa et seq ed supp umwa bcoa negotiated new agreement finance benefits nbcwa created four trusts replaced benefit plans quickly developed financial problems thus parties executed another nbcwa agreement assigned responsibility health care active retired employees respective coal mine operators signatories earlier nbcwas left benefit plan effect retirees whose former employers longer business nonetheless financial problems continued plague plans costs increased employers signed nbcwa withdrew agreement either continue business nonunion employees exit coal business altogether coal operators abandoned benefit plans remaining signatories forced absorb increasing cost covering retirees left behind exiting employers ibid pursuant yet another nbcwa umwa bcoa attempted remedy problem time imposing withdrawal liability nbcwa signatories seceded benefit plans despite efforts plans remained serious financial crisis june individuals received health benefits funds danger losing benefits frieden congress ponders fate coal miners fund business health hereinafter frieden individuals retired miners dependents whose former employers longer contributing benefit plans another worked employers longer never karr union nonunion coal companies head showdown retirement benefits wall street journal mar hereinafter karr troubles aggravated rising health care costs frieden umwa threatened strike legislative solution reached karr bcoa members included coal firms currently signatories nbcwas threatened renew commitments cover retiree costs contracts expired ibid following another strike much unrest secretary labor elizabeth dole created advisory commission mine workers america retiree health benefits coal commission studied problem proposed several solutions eastern enterprises particular coal commission focused finance health care benefits orphaned retirees congress considered proposals eventually reconfigured allocation health benefits coal miner retirees enacting coal act crafting legislative solution crisis however easy task coal act passed amidst maelstrom contract negotiations strike threats presidential veto first version threats second veto high pressure mention wide disagreements among members congress act merged benefit plans new multiemployer plan called mine workers america combined benefit fund combined fund see combined fund financed annual premiums assessed signatory coal operators coal operators signed nbcwa agreement requiring contributions benefits plans eastern enterprises signatory longer business statute assigns liability defined group related persons ibid see coal act charged commissioner social security assigning eligible beneficiary signatory operator related persons statute identifies specific categories signatory operators related persons requires commissioner assign beneficiaries among categories particular order ibid coal act also ensures beneficiary remains unassigned existing company falls within aforementioned categories benefits financed combined fund either funds transferred interest earned department interior abandoned mine reclamation fund additional premium imposed assigned signatory operators pro rata basis see ii respondent jericol formed irdell mining irdell shortly thereafter irdell another company purchased coal mining operating assets shackleford coal company company signatory coal wage agreement business sigmon coal apfel supp wd acquired right use shackleford name assumed responsibility shackleford outstanding contracts including agreement umwa app common ownership irdell shackleford irdell subsequently changed name operating shackleford coal company changed name jericol new company signatory nbcwa acting pursuant commissioner assigned premium responsibility retired miners dependents jericol assigned worked shackleford commissioner determined successor successor interest original shackleford jericol qualified related person shackleford others assigned actually worked jericol jericol appealed commissioner arguing assignments erroneous jericol successor interest shackleford jericol related person see pet cert dissatisfied outcome administrative proceedings sigmon coal company jericol filed suit commissioner arguing wrongfully assigned retirees dependents jericol supp district concluded classification regime coal act provide directly indirectly liability laid door successors defunct signatory operators district ordered commissioner withdraw challenged assignments enjoined commissioner assigning additional retirees jericol basis related person original shackleford commissioner appealed arguing straight reading statute shows successor interest signatory operator qualifies related person thereby permitting assignment retirees dependents jericol alternatively commissioner argued district reading produces inexplicable anomalous results clearly odds congressional intent ibid eclin ing commissioner invitation rewrite coal act appeals fourth circuit affirmed appeals concluded statute clear unambiguous bound read exactly written ibid accordingly held jericol related person shackleford thus held responsible shackleford miners appeals rejected commissioner arguments reading either contravenes congressional intent begets fairly odd results rather appeals found plausible jericol explanation plain text act consistent congress desire promote sale coal companies respond complaints coal operators required pay benefits retired miners neither worked maintained relationship plausible explanation concluded need reject assertion coal act definition related person face absurd alternatively reasoned even literal text statute produced arguably anomalous result simply free ignore unambiguous language imagine preferable version ibid one rare cases concluded congress drafted statute produced absurdity gross shock general moral common sense ibid quoting maryland dept ed department veterans affairs granted certiorari affirm iii statutory construction cases begin language statute first step determine whether language issue plain unambiguous meaning regard particular dispute case robinson shell oil citing ron pair enterprises inquiry ceases statutory language unambiguous statutory scheme coherent consistent respect question presented case statute unambiguous statutory text instructs coal act permit commissioner assign beneficiaries successor interest signatory operator statute provides purposes chapter commissioner social security shall october assign coal industry retiree eligible beneficiary signatory operator related person respect remains business following order first signatory operator signatory coal wage agreement subsequent coal wage agreement recent signatory operator employ coal industry retiree coal industry least years second retiree assigned paragraph signatory operator signatory coal wage agreement subsequent coal wage agreement recent signatory operator employ coal industry retiree coal industry third retiree assigned paragraph signatory operator employed coal industry retiree coal industry longer period time signatory operator prior effective date coal wage agreement case commissioner determined shackleford signatory employed disputed miners months assignment must made category assigned miners jericol determining jericol successor interest shackleford therefore related person shackleford disagree commissioner reasoning disputed retirees employees shackleford signatory operator sold assets jericol commissioner assign jericol related person shackleford statute provides person shall considered related person signatory operator person falls within one three categories member controlled group corporations within meaning section includes signatory operator ii trade business common control determined section signatory operator iii person identified partnership interest joint venture signatory operator business within coal industry business employed eligible beneficiaries except clause shall apply person whose interest limited partner addition last sentence related person shall also include successor interest person described clause ii iii although commissioner maintains jericol related person shackleford jericol fall within three specified categories defining related person contention ever member controlled group corporations including shackleford ever business common control shackleford ever partnership interest engaged joint venture shackleford therefore liability beneficiaries may attach jericol successor interest entity described iii jericol successor interest shackleford jericol liable signatory operator shackleford falls within one categories none three categories however includes signatory operator infer much general principle statutory construction congress includes particular language one section statute omits another section act generally presumed congress acts intentionally purposely disparate inclusion exclusion russello quoting wong kim bo congress wanted provide successor liability coal act explicitly demonstrated sections act give option attaching liability successors successors interest example provides respect beneficiaries combined fund person becomes successor assigned operator enactment date coal act assigned operator may transfer assignment eligible beneficiary successor successor shall treated assigned operator respect eligible beneficiary purposes chapter emphasis added subsection also provides however assigned operator transferring assignment related person shall remain guarantor benefits provided eligible beneficiary chapter ibid provision gives postenactment successor option transferring assignment assuming signatory operator liability address liability preenactment successors enumerates continuing obligations individual employer plans ieps maintained pursuant subsequent coal wage section provides purposes ieps umwa benefit plan term last signatory operator shall include successor interest operator thus congress gave last signatory operator definition extends iep obligations preenactment signatory operator include successors interest subsections stand direct contrast provisions implicated define signatory operator related persons last signatory operator respectively purposes section specify include impose liability signatory operator successor interest despite unambiguous language statute respect entities successor liability attaches commissioner essentially asks read statute mandatory liability preenactment successors interest signatory operators refrain concluding differing language two subsections meaning presume ascribe difference simple mistake draftsmanship russello supra congress wrote statute manner provides liability successors interest certain signatory operators congress meant make preenactment successor interest like jericol liable done clearly explicitly therefore statute explicit may assigned liability beneficiaries neither related persons provision provision successors interest signatory operators may assigned liability plain language statute necessarily precludes commissioner assigning disputed miners jericol iv commissioner admits statute state haec verba assignment may made direct successor interest entity signatory operator brief petitioner nonetheless commissioner concludes light text structure purposes coal act direct successors interest included within liability scheme responsible signatory operator combined fund premiums signatory operator defunct related person still business ibid address commissioner arguments commissioner proposes several readings statute first commissioner argues last sentence term related person include successor interest person described clause ii iii clauses mention signatory operator signatory operator described clause virtue express reference brief petitioner text statute support reading congress wanted include successors interest clearly explicitly see supra category related persons describes definitive group persons congress neither created separate category signatory operators included signatory operators within categories unlikely congress intended attach liability group successors interest signatory operators general clause meant reach persons described one three explicit categories second commissioner argues signatory operator necessarily member controlled group corporations includes brief petitioner subsection provides related persons include member controlled group corporations within meaning section includes signatory operator thus according commissioner logic corporation member controlled group includes corporations successor interest member group corporations includes successor interest corporation ibid standing alone subsection supports commissioner argument signatory operator necessarily member group corporations includes provision divorced clause begins related persons provision person shall considered related person signatory operator person emphasis added commissioner reading signatory operator related makes little sense say related person makes little sense say signatory operator related person statute therefore necessarily implies related person separate entity signatory operator moreover commissioner argument works signatory operator actually part controlled group corporations commissioner account situation signatory operator part controlled group commissioner contend shackleford part controlled group corporations argument event force commissioner also contends background legislative history purposes coal act confirm congress intended liability signatory operator employees placed signatory direct successor interest support commissioner turns floor statements senators malcolm wallop jay rockefeller arguing senators sponsored coal act views entitled special weight particular commissioner relies explanation legislation placed record senator wallop making point addition three categories related persons statute provides related persons includes iv specific instances successors collective bargaining agreement obligations signatory operator cong rec commissioner also points senator rockefeller statement term signatory operator defined new section includes successor interest operator floor statements two senators amend clear unambiguous language statute see reason give greater weight views two senators collective votes houses memorialized unambiguous statutory commissioner also argues construing related person provision exclude signatory direct successor interest contrary congress stated purpose ensuring combined fund beneficiary health care costs borne possible person direct responsibility beneficiary persons connection beneficiary public fisc commissioner contends choose construction statute effectuates congress overriding purpose avoiding recurrence orphan retiree catastrophe caused large part operators avoiding responsibility beneficiaries changing corporate structures selling assets ceasing operations see brief petitioner commissioner suggests appeals construction statute leads result direct successor interest signatory may made responsible signatory beneficiaries even though successor liability supported background principles distantly related successor interest corporate affiliate signatory operator may made responsible signatory beneficiaries thus commissioner appears request invoke form absurd results test citing video brown respondents correctly note rarely invokes test override unambiguous legislation moreover respondents offer several explanations congress purposefully exempted successors interest signatory operator related person definition first respondents argue coal operators undoubtedly opposed legislation seriously expanded liability respect miners never hard imagine signatory companies agreed compromise exposed statutory liability linked decades buying selling trading property brief respondents second respondents speculate congress may concluded injecting coal industry successor issues commissioner task allocating liability umwa retirees dependents consume disproportionate share agency resources create gridlock assignment process precipitate endless operator challenges coal act administrative review process thwart implementation program finally respondents suggest congress concerned adverse impact successor liability might valuation sale union companies statutory language clear biguous need neither accept reject ular plausible explanation congress written statute imposes liability successors companies fall within categories iii successors signatory operators dissatisfied text statute commissioner attempts search apply overarching legislative purpose section statute dissatisfaction however often cost legislative compromise negotiations surrounding enactment bill tell typical story legislative battle among interest groups congress president see supra nn indeed legislation failed ease tensions among many interested delicate crafting reflected compromise amidst highly interested parties attempting pull provisions different directions see legislative history change individual provision unraveled whole quite possible bill assigned liability successors signatory operators survived legislative process deals brokered committee markup floor two houses joint house senate conference negotiations president us judge role interpret language statute enacted congress statute contain conflicting provisions ambiguous language require narrowing construction application canon interpretative tool stated time courts must presume legislature says statute means means statute says words statute unambiguous first canon also last judicial inquiry complete connecticut nat bank germain quoting rubin internal citations omitted alter text order satisfy policy preferences commissioner battles fought among political branches industry parties seek amend statute appeal judicial branch commissioner final argument even coal act affirmatively provide responsibility combined fund premiums may imposed signatory direct successor reasonable commissioner conclude direct successors signatory operator responsible operator employees congress however delegate authority commissioner develop new guidelines assign liability manner inconsistent statute context unambiguous statute need contemplate deferring agency interpretation see chevron natural resources defense council accordingly judgment appeals affirmed ordered jo anne barnhart commissioner social security petitioner sigmon coal company et al writ certiorari appeals fourth circuit february justice stevens justice justice breyer join dissenting case raises question whether clear evidence coherent congressional intent inform construction statutory provision seems first blush convey incoherent message today majority chooses disregard evidence instead adheres interpretation statute produces absurd results two members congress sponsors legislation issue explained statute mandate results agency charged administering statute agrees partner two branches government heed reasonable interpretation congress objectives coal industry retiree health benefit act coal act act et seq ed supp authorizes commissioner social security commissioner assign responsibility providing health care benefits certain retired coal miners beneficiaries enacted response financial difficulties plagued national bituminous coal wage agreements nbcwas private health care system established representatives coal industry mine workers association umwa see eastern enterprises apfel nbcwas part arrangement umwa accepted bargaining agreements dictating wages benefits terms employment exchange inter alia promises regarding provision lifetime health benefits retired miners many coal operators signatories nbcwas went business withdrew coverage remaining signatories forced assume share health care costs operators employees consequently remaining members even greater incentive avoid obligations agreements ibid ensuing downward spiral threatened nbcwas ability provide health benefits evaluating legislative solutions congress advised retirees might receive benefits promised process quoting coal commission report health benefits retired coal miners hearing subcommittee medicare care senate committee finance statement bituminous coal operator association chairman michael reilly congress objective passing coal act identify persons responsible plan liabilities establish order priority ensure viability fund energy policy act pub stat accomplish goal act directs commissioner assign primary responsibility signatory operator formerly employed particular miners persons related operator broad definition term related person includes three classes entities associated signatory catchall sentence stating related person shall also include successor interest person described clause ii iii question case whether act permits commissioner assign retirees successor signatory successors related persons signatory commissioner reads statute broadly include direct successors whereas adopted narrower reading excludes responsibility signatory operator described clause ii iii concludes successor interest signatory liable retirees predecessor catchall provision thus reads act assign liability first signatory operator assuming still business related persons signatory none exists still business successor interest related person liability never assigned direct successor logical recipient liability signatory two examples illustrate absurdity reading first imagine corporations operate coal mines kentucky illinois respectively affiliated corporations let us say members controlled group corporations company became signatory one coal agreements subsequently sell assets separate purchasers reading act purchaser kentucky mines responsible health care costs illinois miners purchaser illinois mines assigned retirees kentucky company neither purchaser liable predecessor retired employees consider slightly different scenario still operates coal mine runs dairy farm still members controlled group corporations however signatory agreement hypothetical sell assets reading statute purchaser dairy farm liable retired miners benefits purchaser coal mine liability result absurd surely incoherent congress order odd result answer simple congress intend result commenting final text bill ultimately enacted two senators sponsoring measure explained understanding statutory text colleagues senator rockefeller west virginia spoke original author legislation cong rec unambiguously stated term signatory operator includes successor interest operator written explanation measure placed congressional record senator wallop stated definition term related person intentionally broad encompassed successors collective bargaining agreement obligations signatory operator assume senators rockefeller wallop correctly understood work product provision coherent obviously sensible impose cost health care benefits successors signatory operators equally obvious far less justification imposing liability successors related companies engaged coal mining moreover assigning liability direct successors consistent congress explicit objective identify persons responsible plan liabilities stat two successor signatory notice may held responsible predecessor liabilities successor related person signatory fact successors signatories nbcwa specifically notice provision agreement employer promise operations covered agreement shall sold conveyed otherwise transferred assigned successor without first securing agreement successor assume employer obligations agreement article national bituminous coal wage agreement direct successor put notice presumably received lower sale price exchange assuming agreement obligations predecessor consider facts case respondent jericol mining purchased coal mining assets shackleford signatory nbcwa sales contract provided jericol assume responsibility shackleford outstanding contracts including agreement app price jericol paid shackleford assets therefore must reflected fact jericol taking shackleford commitments retirees allowing jericol escape responsibility end bargain stage effectively grants windfall trumpets clear language statute language clear enough require disregard clearly expressed legislative intention contrary consumer product safety gte sylvania require us accept absurd results turkette citing trans alaska pipeline rate cases see infra nevertheless accepts respondents claim even statute produces odd results scheme product legislative compromise override drafters according theory may confronted significant opposition successors signatories faced liability alternative language congress may concerned imposing liability successors create disincentive potential purchasers coal companies assets negotiations contentious respondents imagine act excluded direct successors product horsetrading one expect response statements two senators directly contradicting terms legislative bargain surely senators disagreed senators rockefeller wallop said something set record straight contrary evidence legislative history compromise respondents amici cite evidence supporting version events respondents counsel asked specifically oral argument tr oral arg total absence suggestion legislative history senators misdescribed coverage act significant see harrison ppg industries rehnquist dissenting case construction legislative language makes sweeping relatively unorthodox change think judges well detectives may take consideration fact watchdog bark night green bock laundry machine scalia concurring judgment confronted statutory language produces absurd result appropriate observe counsel provided discovered shred evidence anyone ever proposed assumed bizarre disposition absent response indicating senators mischaracterized act construe statute light clear purpose thereby avoid absurd results majority countenances indeed cavalier treatment explanations statute provided colleagues senators rockefeller wallop disrespectful senators entire senate well although say explicitly apparently assumes senators either dissembling unable understand meaning bill sponsoring neither assumption tenable much likely simple explanation senators quite reasonably thought term signatory operator included successors account certainly consistent congress instructions dictionary act reference corporation may embrace successors assigns even expressly mentioned coal act defines signatory operator person signatory coal wage agreement term person defined according dictionary act includes corporations companies associations firms partnerships societies joint stock companies well individuals know word company association used reference corporation shall deemed embrace words successors assigns company association like manner words words similar import expressed therefore reading term signatory operator encompass direct successors compatible default rules congress provided interpreting statutes context indicate otherwise congress clearly authorized commissioner assign retirees successors extending liability category successors consistent purpose act cf rowland california men colony unit ii men advisory council recognizing even contextual features contradict dictionary act reading interpretation may appropriate make little sense adopt literal reading wilson omaha tribe trucking three additional considerations support reading act cover direct successors first reading consistently endorsed several commissioners responsible administration act notwithstanding change control executive previously attached significance fact new administration took office agency concluded statutory term given definition chevron natural resources defense council second consistent treatment successorship issues labor cases required successors bargain union certified predecessor see fall river dyeing finishing nlrb assume liability reinstatement backpay result predecessor unfair labor practice see golden state bottling nlrb arbitrate disputes provided predecessor agreement see john wiley sons livingston finally avoid adopting interpretation statute recreates difficulties beset nbcwas congress explicitly sought avoid immediate consequence reading retired miners unassigned therefore health care expenses borne remaining signatory operators related persons assuming retired miners category today decision result orphaned miners draw combined fund extent cost health benefits passed along signatory operators holding creates added incentive remaining signatories avoid obligations agreements result effectively downward spiral doomed eastern judgment holding case product misguided approach issues statutory construction text statute provides us evidence usually sufficient disclose intent enacting congress always case occasions exclusive focus text seems convey incoherent message reliable evidence clarifies statute avoids apparent incoherence case one never permit narrow focus text obscure commonsense appraisal additional evidence respectfully dissent footnotes signatory operator coal operato signed national bituminous coal wage agreement agreement requiring contributions benefit plans eastern enterprises apfel see also ed term signatory operator means person signatory coal wage agreement eastern enterprises discussed great length history negotiations coal industry umwa provision employee benefits coal miners provide brief summary trusts included umwa benefit plan trust benefit plan provided nonpension benefits including medical benefits miners retired january umwa benefit plan trust benefit plan provided benefits active miners retired term orphan retirees encompassed true orphans whose former employers longer business reachback orphans whose former employers still business longer signatories coal wage agreement possibly longer coal business house committee ways means development implementation coal industry retiree health benefit act comm print hereinafter development see mcglothlin connors wd lawsuit involved beneficiaries benefit plan benefit plan trustees bcoa district judge encouraged zealously seek passage bill congress permit transfer funds possession trustees excess future projected needs finance benefit trusts original proposal introduced senator jay rockefeller benefits financed taxes entire coal industry premiums collected reachback companies considered responsible specific orphans development support umwa bcoa private benefits alliance pba group nonunion companies congress originally passed bill part comprehensive tax package see karr president bush however vetoed entire package part coal tax provisions tax package veto kills bailout plan rockefeller vows find another way mine regulation reporter mar wl members congress continued push legislation using comprehensive energy bill vehicle senator rockefeller attempted add coal tax provision energy bill measure strongly opposed number senators bush administration cloture motion energy bill fails dole says resolution dispute controversial coal tax may near bush threatens veto remains foster natural gas report july much negotiation final version bill include tax provision provided companies party nbcwas required cover retiree health costs senate adopts compromise amendment funding miner health benefits bna daily labor report july umwa bcoa example joined forces support legislation require nonunion companies share cost providing health benefits thereby shifting burden paying funds entire industry contrast pba alliance nonunion companies insisted never employed retirees forced pick companies obligations karr term beneficiary refers individual coal industry retiree july eligible receive receiving benefits umwa benefit plan umwa benefit plan date eligible receive receiving benefits either plan reason relationship retiree jericol appeal recent assignment commissioner arguing already filed suit required exhaust administrative remedies seeking relief given similarity law facts underlying assignment shackleford miners jericol district agreed sigmon coal apfel supp wd case reviewing whether jericol related person shackleford sigmon coal joined jericol plaintiff apparently related persons coal act ed thus jointly severally responsible amounts due either see supp rules applicable successors signatory operators maintain plans provided discusses obligations person becomes successor last signatory operator postenactment nearly identical placed proper context statement entirely consistent statutory text senator wallop noted first bill makes related person fully responsible signatory operator obligation provide benefits act signatory longer business otherwise fail fulfill obligations act cong emphasis added listing three categories related persons senator wallop added category iv specific instances successors collective bargaining agreement obligations signatory operator equally obligated signatory operator pay continuing health care coverage ibid emphasis added begin must noted senator wallop state successors responsible beneficiaries rather narrowed group qualifying phrase specific instances senator wallop suggest responsibility attaches successors interest signatory operators instead successors collective bargaining agreement obligations nothing entities previously identifies fully responsible signatory operator obligation related persons categorized clauses iii consequently statement consistent final sentence related persons definition provides related person shall also include successor interest person described clause ii iii need look statutory text know definition fact include successor interest see term signatory operator means person signatory coal wage agreement see supra despite dissent assertion defer characterizes clear evidence coherent congressional intent post opinion stevens dissent points two sentences congressional record even believe floor statements amend clear statutory language statements hardly characterized clear evidence begin dissent mischaracterizes senator wallop statement neglecting explain context include qualifying phrase specific instances see supra absent support senator wallop statement dissent left senator rockefeller explanation dissent essentially contends use single sentence long colloquy affect major change statute however dissent fails note house passed bill october three days senator rockefeller made statement see legislative history energy policy act committee print compiled senate committee energy natural resources library congress hereinafter legislative history indication senator rockefeller version provision garnered support house senate president given house already passed bill dissent additional reliance absence response senators explanation simply makes sense see post moreover adopt form statutory interpretation placing obligation members congress monitor colleague floor statements read every word congressional record including written explanations inserted record evidence need rely clear statutory text commissioner asks apply background principles successorship articulated treatment labor employment benefit statutes corporate entity liability statutory scheme attributed entity direct successor interest brief petitioner coal act congress expressly delineated parties sought attach responsibility statute provides explicit scheme include successors interest signatory operators indication congress intended statute supplemented reference background principles import principles analysis dissent makes conclusory assertion interpretation statute recreates difficulties beset nbcwas congress explicitly sought avoid see post dissent however provides data conclusory assertion explain interpretation recreates ties beset nbcwas ibid dissent ignores fact new scheme broadly expanded group persons responsible beneficiaries thus fact congress declined attach liability one group persons tells us nothing new system viability respondents argue successor liability covering years transactions exploded number combined fund beneficiaries potentially assignable signatory operators see brief respondents difficult signatories estimate potential liability legislative fix included successor liability thousands umwa retirees potential candidates assignment nbcwa signatory broad based successor liability congress retroactively burdened coal asset purchasers financial shortfalls arising failures private party contract respondents argue future purchasers wary paying fair market value coal property concerns might destabilize unionized industry economic underpinning time many assigned operators might need raise money help defray costs imposed act umwa lobbying efforts precipitated lawsuit pittson coal company sued umwa million alleging conclusion strike union promised lobby behalf legislation making reachback companies resume payments retiree health system umw denies breaching pittston pact coal outlook wl pittston accused union violating promise lobby industry wide taxation bail two retiree health funds umw pittston reach tentative deal coal outlook june wl footnotes ed provides person shall considered related person signatory operator person member controlled group corporations within meaning includes signatory operator ii trade business common control determined signatory operator iii person identified partnership interest joint venture signatory operator business within coal industry business employed eligible beneficiaries except clause shall apply person whose interest limited partner related person shall also include successor interest person described clause ii iii particular interest limit scope potential assignees three subparagraphs stated ecause complex corporate structures often found coal industry number entities made jointly severally liable signatory operator obligations definition related persons intentionally broad regard term related person defined broadly include companies related signatory operator conference agreement makes related person fully responsible signatory operator obligation provide benefits act signatory longer business otherwise fail fulfill obligations act thus statute provides related persons meaning within controlled group corporations including signatory operator using common ownership test ii trade business common control signatory operator iii one partnership interest joint venture signatory operator iv specific instances successors collective bargaining agreement obligations signatory operator equally obligated signatory operator pay continuing health care coverage cong rec emphasis added meaning senator wallop reference specific instances evident surely mean instances seems assume see ante phrase successors collective bargaining agreement obligations signatory operator refer successors persons described clauses iii members controlled group corporations example assume agreement obligations specific instances however direct successors signatory operators may assume obligations see infra senator wallop emphasized point clarifying liability intentionally broad cong explained purpose provision insure every reasonable effort made locate responsible party provide benefits cost passed signatory companies never connection individual allocation beneficiaries entity business continues business basic statutory intent thus conference agreement overriding purpose find designate specific obligor many beneficiaries plans possible ibid although social security administration interpreted meaning successor differently time taking different positions whether asset purchaser qualifies successor consistently taken position direct successor assigned responsibility signatory employees see provisions relating health benefits retired coal miners hearing house committee ways means statement commissioner lawrence thompson explaining miners assigned last active signatory operator successor operator business miner worked letter ssa southeastern program service center app uccessors successors interest treated assignment purposes change ownership supplemental coal act review instructions july app pet cert coal act permit assignments successors defunct inactive signatory operators first three years act health care costs orphaned miners shared among signatories starting fourth year payment deducted first interest earned department interior abandoned mine reclamation fund aml funds exhausted unavailable costs shared remaining signatories availability interest transfers may delay another financial crisis noted aml funds earmarked purposes see ed crs report coal industry use abandoned mine reclamation fund monies umwa orphan retiree health benefits cong rec first priority goes mining abandonments present imminent danger public health safety remaining aml funds designated eliminate environmental hazards moreover given high cost health care retired miners likely diminution fund interest earning capacity see interest may last long