In Southern Appalachian Mountain Stewards v. Red River Coal Co., ___ F.3d ___, No. 19-2194, 2021 WL 1182464 (4th Cir. 2021), the U.S. Court of Appeals for the 4th Circuit held that Red River Coal Company's (Red River) compliance with its Clean Water Act permit shielded Red River from liability under the Surface Mining Control and Reclamation Act. Several citizens' groups brought suit against Red River for discharges of pollutants from the inactive North Fox Gap Surface Mine in Virginia. Those discharges were permitted by Red River's Clean Water Act permit. The citizens' groups alleged that the discharges violated the Surface Mining Act's