MOSenecaManufacturer, LLC v. MSHR
CourtCourt of Appeals for the Eighth Circuit
Date FiledAugust 7, 2026
Docket25-1349
StatusPublished
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Full Opinion
United States Court of Appeals
For the Eighth Circuit
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No. 25-1349
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MOSenecaManufacturer, LLC, doing business as American Tripoli
Petitioner
v.
Federal Mine Safety and Health Review Commission; Secretary of Labor
Respondents
____________
Petition for Review of an Order of the
Federal Mine Safety and Health Review Commission
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Submitted: January 15, 2026
Filed: August 7, 2026
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Before SHEPHERD, KELLY, and STRAS, Circuit Judges.
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KELLY, Circuit Judge.
MOSenecaManufacturer, LLC d/b/a American Tripoli (American Tripoli)
filed a petition for review of the Federal Mine Safety and Health Review
Commission’s (Commission) order dismissing its proceeding for failure to comply
with a prior order, as well as the Commission’s order denying American Tripoli’s
motion for reconsideration. In its briefing, however, American Tripoli presses only
constitutional arguments related to a merits decision by an Administrative Law
Judge (ALJ). Accordingly, we dismiss the petition.
I.
Robert Baumann worked at a mine owned by American Tripoli and was
elected miner representative in March 2023. On April 11 and 12, 2023, Baumann
participated in an inspection with a Mine Safety and Health Administration (MSHA)
inspector, and MSHA issued a withdrawal order pursuant to Section 104(b) of the
Federal Mine Safety and Health Act of 1977 (Mine Act). American Tripoli
terminated Baumann less than a week later. Baumann then filed a complaint with
MSHA, and on April 25, 2023, the Secretary of Labor brought a case on his behalf,
alleging discrimination and interference under Section 105(c) of the Mine Act.
On May 23, 2024, an ALJ found American Tripoli violated Section 105(c) of
the Mine Act and ordered it to pay $10,552 in backpay to Baumann in addition to
$32,500 in civil penalties. On June 18, 2024, pursuant to 30 U.S.C. § 823(d)(2)(B),
the Commission sua sponte directed review of the ALJ’s decision. A few days later,
on June 21, 2024, American Tripoli filed its own petition for discretionary review.
On June 27, 2024, the Commission granted American Tripoli’s petition for
discretionary review, see 30 U.S.C. § 823(d)(2)(A)(i), combined it with the sua
sponte direction for review, and set a briefing schedule.
While American Tripoli’s petition to the Commission was pending, it filed a
“Motion to Cease and Desist Enforcement Actions Pending Final Judgment” dated
October 31, 2024. On November 22, 2024, the Commission ordered American
Tripoli to submit copies of two cases it relied upon in its motion, which the
Commission could not locate, and to do so before December 6, 2024. American
Tripoli did not submit the copies by the deadline.
On December 23, 2024, the Commission ordered American Tripoli to show
cause “why the Commission should not vacate its directions for review and dismiss
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this proceeding,” given American Tripoli’s failure to submit copies of the two cases
named in the Commission’s November 22 order.
American Tripoli responded to the Commission’s Order to Show Cause on
January 9, 2025. But it did not submit copies of the two cases. Instead, American
Tripoli argued that the inclusion of these cases “was inadvertent and unintentional”
and “[did] not impact the substantive legal arguments presented in this matter.”1
Although it purported to attach supplemental caselaw to that response, it did not do
so.
On January 17, 2025, the Commission issued an order vacating the directions
for review and dismissing the proceeding. The Commission “conclude[d] that
[American Tripoli] fabricated cases in its filings to the Commission,” noting that
American Tripoli “offer[ed] no explanation for [its] failure to timely respond to the
Commission’s November Order,” did not “provide[] copies of the cases upon which
it purportedly relied,” and failed to attach the supplemental caselaw it claimed to
rely on in its January 9 response. American Tripoli then filed a motion for
reconsideration on January 19, 2025, which the Commission denied in a summary
order on February 12, 2025.
On February 18, 2025, American Tripoli filed in this court a petition for
review of the Commission’s “final order issued on January 17, 2025, and the denial
of reconsideration issued on February 12, 2025.” American Tripoli attached the
Commission’s January 17, 2025, order vacating the directions for review and
dismissing the proceeding and the Commission’s February 12, 2025, order denying
reconsideration of its January 17 order. American Tripoli did not name or attach any
other order from the ALJ or Commission in its petition for review. American Tripoli
subsequently obtained counsel for this appeal, who filed their appearances on March
5, 2025.
1
At oral argument, counsel for American Tripoli speculated that the two cases
were “AI hallucinations.”
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American Tripoli now advances several constitutional arguments not
presented to the ALJ who adjudicated its merits proceeding, but we need not decide
them today because American Tripoli failed to properly designate the ALJ’s decision
in its petition for review before this court.
II.
Federal Rule of Appellate Procedure 15(a)(2)(C) requires petitions for direct
review of agency action to “specify the order or part thereof to be reviewed.” Fed.
R. App. P. 15(a)(2)(C). “Failure to specify the correct order can result in dismissal
of the petition.” Entravision Holdings, LLC v. FCC, 202 F.3d 311, 312 (D.C. Cir.
2000); see also City of Benton v. Nuclear Reg. Comm’n, 136 F.3d 824, 826 (D.C.
Cir. 1998). It is undisputed that American Tripoli designated only two orders in its
petition for review: the Commission’s January 17, 2025, order vacating the
directions for review and dismissing the proceeding, and the Commission’s February
12, 2025, order denying reconsideration of its January 17 order. In so designating,
American Tripoli gave notice it would contest the Commission’s decision to vacate
the directions for review and dismiss the case based on American Tripoli’s failure
to comply with prior orders of the Commission. But American Tripoli’s briefing
before this court instead argues constitutional issues relevant to its merits
proceedings before the ALJ.
American Tripoli did not designate or otherwise reference the ALJ’s decision
in its petition for review before this court. But a “mistaken . . . specification of the
order to be reviewed will not be fatal to the petition . . . if [American Tripoli’s] intent
to seek review of a specific order can be fairly inferred from the petition for review
or from other contemporaneous filings, and the respondent [would] not [be] misled
by the mistake.” 2 Entravision Holdings, 202 F.3d at 313; see also Snohomish County
2
We note that “the lack of prejudice is a necessary, not sufficient, condition
for excusing a petitioner’s mistake in naming the order of which review is sought[.]”
Sinclair Broad. Grp., Inc. v. FCC, 284 F.3d 148, 157 (D.C. Cir. 2002) (quoting Sw.
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v. Surface Transp. Bd., 954 F.3d 290, 300 (D.C. Cir. 2020) (“[O]ur examination of
compliance with Rule 15(a) is not formalistic.”). In American Rivers v. FERC, for
example, the D.C. Circuit concluded that a petitioner’s intent to seek review of
multiple orders not cited in its petition for review “can be fairly inferred from the
motion to consolidate the two petitions for review, the docketing statement, the
statement of issues, and the underlying decisions attached to the appeal.” 895 F.3d
32, 44 (D.C. Cir. 2018); see also Kazarian v. Bondi, 159 F.4th 690, 691–93 (9th Cir.
2025) (petitioner’s misstatement of date of challenged order and failure to attach a
copy of challenged order not fatal to petition for review where petitioner’s
contemporaneous motion to stay and petition “make clear that he seeks review of”
the challenged order).
Courts have also found that an intent to seek review of a specific order can be
fairly inferred when the petition itself mentions or refers to the merits of that order.
See, e.g., Sinclair, 284 F.3d at 158 (issue listed in filed petition for review “c[ould]
only refer to the [omitted order], and thus gave notice to a reasonably intelligent
person that [petitioner] intended to make a substantive challenge to the [omitted
order] and not only to the [designated order]”); Bhd. of Locomotive Eng’rs &
Trainmen v. Fed. R.R. Admin., 972 F.3d 83, 110–11 (D.C. Cir. 2020) (filed petition
for review adequately presented issue where it included specific language
challenging Railroad Administration decision); Muir v. U.S. Dep’t of Homeland
Sec. & Transp. Sec. Admin., 145 F.4th 1359, 1370–71 (D.C. Cir. 2025) (filed
petition for review adequately presented issue for review even though reference to
standard operating procedure was omitted).
Here, American Tripoli did not mention or refer to any merits-related issues
in its petition for review. And American Tripoli submitted no contemporaneous
filings that fairly demonstrated its intent to seek review of the ALJ’s merits decision,
rather than the orders it actually identified: the Commission’s discrete decisions to
Bell Tel. Co. v. FCC, 180 F.3d 307, 314 (D.C. Cir. 1999), abrogated on other
grounds by Entravision Holdings, 202 F.3d at 313 n.**).
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dismiss the proceeding for failure to comply with the order to show cause and to
deny reconsideration. We therefore cannot “fairly infer” American Tripoli’s “intent
to seek review” of the ALJ’s merits decision. See Entravision Holdings, 202 F.3d at
313–14.
III.
Accordingly, we dismiss American Tripoli’s petition for review. 3
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3
We deny as moot the Secretary of Labor’s motions to dismiss and to file a
supplemental appendix.
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