Earlier this month, the United States Court of Appeals for the Seventh Circuit affirmed a lower court decision finding that a mineral deed granting "all the coals, clays, minerals and mineral substances underlying" the defendants' land, "together with the right to mine and remove said coals," did not grant the right to strip mine the land. See American Land Holdings of Indiana, LLC v. Jobe (Case Nos. 09-3151, 09-3265), here. Particularly significant to the court was the state of technology at the time - Permitted extrinsic evidence showed that there was no strip mining of coal anywhere in the United States beyond isolated experimentation.