In northern Minnesota, a gripping legal battle unfolds as the Range Association of Municipalities and Schools (RAMS) teams up with Mountain States lawyers to support Twin Metals Minnesota in the company’s lawsuit against illegal agency actions. In 2022, the Biden Administration took drastic measures to terminate the Twin Metals mining project, a game-changing project in northeastern Minnesota focusing on deposits of important clean energy minerals, including copper, nickel, cobalt and platinum group metals, sparking concerns about whether the government adhered to proper procedures in doing so. As a result, Twin Metals sued the government, citing violations to the Administrative Procedure Act, as the outcome carries immense weight, impacting not only Twin Metals, but also jobs, schools, and the regional economy. Unfortunately, the district court dismissed Twin Metals’ lawsuit, favoring the government. Now, Twin Metals has appealed, seeking justice at a higher court. And RAMS and Mountain States are coming to support their cause via amicus briefs.  

The implications of this case extend far beyond Minnesota, potentially affecting America’s supply of critical minerals, increasing dependency on foreign sources, and disrupting the balance of power among government branches, with broad consequences beyond mining. 

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Status

Court

United States Court of Appeals

Representation

Amicus

Case Background

In the Iron Range region of Minnesota, RAMS is a pillar of local advocacy. Established in 1939, RAMS represents many cities, townships, and schools in northeastern Minnesota, tirelessly working to advance community development and improve its members’ quality of life. RAMS’ mission revolves around monitoring legislation and collaborating with local governments to foster economic and social growth in the region, resulting in frequent issues calling for collaboration with or opposition to federal and state regulators. With their sweeping regulatory authority over the lands in northeastern Minnesota, these agencies have often clashed with RAMS over issues critical to the local communities. 

The current conflict centers on the Twin Metals project, a proposed mining venture in the Superior National Forest. Twin Metals, holding mineral rights in the area for over 50 years, planned to construct a state-of-the-art underground mine. Its leases, dating back to 1966 and renewed as recently as 2019, were seen as a cornerstone for economic revitalization in the Iron Range. However, in 2022, the Biden Administration took dramatic steps to halt the project in the form of lease cancelations, denying Twin Metals’ applications for additional leases, and rejecting Twin Metals’ mining proposal, claiming it was incomplete due to the inclusion of the disputed lands, only to later reject a revised submission. 

These actions prompted Twin Metals to sue, arguing the government’s decisions were illegal and unreasonable under the Administrative Procedure Act (APA), an act that sets standards for how federal agencies must conduct their decision-making processes. Under the APA, agency actions must provide rational explanations for their decisions, based on relevant data and consistent with their prior statements and legal mandates. Additionally, agencies must act within the scope of their authority as defined by Congress and other applicable laws. 

Twin Metals asserts that the government’s abrupt decision to cancel the leases, reject the lease applications, and dismiss the mine proposal is not only baseless (making it unreasonable) but also a blatant disregard for established legal principles (making it illegal). This reckless move undermines the rights granted to Twin Metals under the initial leases and their subsequent renewals. By acting without a sound basis in fact or law, the federal government is undermining the legal framework meant to ensure procedural integrity. This reckless approach sets a dangerous precedent, eroding the foundational trust and reliability that the businesses and communities in the Iron Range rely on.  

For the good of the Iron Range, RAMS has put heavy effort and time into supporting the Twin Metals project. In filing a “friend of the court” brief to tell RAMS’ perspective, Mountain States has explained to the appellate judges how RAMS has advocated for the creation of thousands of well-paying jobs and significant tax revenue to support local schools and government services in the region. Mountain States, dedicated to combating federal overreach and defending local rights, argues for RAMS that the government’s actions were unlawful, unreasonable, and economically detrimental. Both organizations seek to overturn the district court’s decision, advocating for a fair review process for Twin Metals’ proposal based on scientific and environmental merits rather than political biases. 

What’s at Stake?

For our client 

For RAMS and the communities it represents, the stakes in this legal battle are exceptionally high. The Twin Metals project promises a lifeline to the Iron Range region of Minnesota. If the government’s actions are upheld and the project remains blocked, the area will miss out on thousands of well-paying jobs and tens of millions of dollars in tax revenue. This revenue is crucial for supporting local schools, government services, and community development efforts. The region, which provided the iron that won World War II, has long suffered from the decline of the steel industry, and it sees the Twin Metals project as a once-in-a-generation opportunity to revitalize its economy and ensure a prosperous future for its residents. RAMS’ and Mountain State’s support for Twin Metals is driven by the potential for significant, positive change for the Iron Range communities, who face a devastating economic blow if the project does not proceed. 

For Americans 

The implications of this case extend far beyond the Iron Range, touching on critical issues that affect all Americans. The district court wrongly dismissed Twin Metals’ case by focusing on the wrong issue. It claimed that only the Court of Federal Claims could hear the case because it involved written approvals for mining. This was a mistake. The APA requires federal regulators to act reasonably and within their legal authority, which they did not do when they rejected Twin Metals’ project. Twin Metals was right to sue in the U.S. District Court for the District of Columbia, not the Court of Federal Claims. The appellate court in Washington, D.C. should reverse the dismissal and order the district court to hear the claims. Allowing the dismissal to stand would set a dangerous precedent, letting federal regulators dodge their legal responsibilities whenever a contract is involved. The American people deserve better. 

Moreover, the outcome of this case has significant implications for America’s supply of critical minerals like copper, nickel, and cobalt. Currently, the United States relies heavily on foreign sources for these minerals, which are essential for various technologies and national security. The Twin Metals site is one of the largest known undeveloped deposits of these minerals in the world. Blocking its development could exacerbate America’s dependency on foreign minerals, posing economic, environmental, human rights, and security risks. 

This case underscores the ongoing struggle between different branches of government and the importance of maintaining a balance of power. A ruling in favor of the federal regulators here could embolden executive agencies to take more drastic actions without a clear congressional mandate, affecting numerous sectors beyond mining, and acting illegally and unreasonably any time they can find some underlying contract that has some tangential relationship to their actions. This is simply untenable, and Mountain States is proud to represent RAMS in saying so at the appellate court. 

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