Director, Office of Workers' Compensation Programs v. Greenwich Collieries

PETITIONER: Director, Office of Workers' Compensation Programs
RESPONDENT: Greenwich Collieries et al.
LOCATION: Colorado Springs, Colorado

DOCKET NO.: 93-744
DECIDED BY: Rehnquist Court (1993-1994)
LOWER COURT: United States Court of Appeals for the Third Circuit

CITATION: 512 US 267 (1994)
ARGUED: Apr 25, 1994
DECIDED: Jun 20, 1994

ADVOCATES:
Edward C. DuMont - on behalf of the Petitioner
Mark E. Solomons - on behalf of the Respondents

Facts of the case

Question

Media for Director, Office of Workers' Compensation Programs v. Greenwich Collieries

Audio Transcription for Oral Argument - April 25, 1994 in Director, Office of Workers' Compensation Programs v. Greenwich Collieries

Audio Transcription for Opinion Announcement - June 20, 1994 in Director, Office of Workers' Compensation Programs v. Greenwich Collieries

William H. Rehnquist:

The opinion of the Court in No. 93-744 will be announced by Justice O'Connor.

Sandra Day O'Connor:

These are two cases.

The Director of the Office of Workers' Compensation Programs, Department of Labor against Greenwich Collieries, and Director of the Office of Workers' Compensation Programs against Maher Terminals, and the cases come to us on writ of certiorari from the United States Court of Appeals for the Third Circuit.

In adjudicating benefits claims under the Black Lung Benefits Act and the Longshore and Harbor Workers' Compensation Act, the Department of Labor applies what it calls the true doubt rule.

This rule essentially shifts the burden of persuasion to the party opposing the benefits claim.

In other words, when the evidence in the case is evenly balanced, the benefits claimant wins.

The administrative law judges in both the cases before us applied the true doubt rule holding that the claimant could prevail because the evidence on both sides was an equipoise.

The Court of Appeals for the Third Circuit reversed in both cases.

In striking down the true doubt rule, the Court of Appeals created a conflict with other Courts of Appeals which had upheld the rule.

We took this case to resolve this conflict.

In an opinion filed today, we affirm the judgment of the Court of Appeals.

We conclude that the true doubt rule violates Section 7(c) of the Administrative Procedure Act which states that the proponent of a rule or order has the burden of proof.

We conclude that the ordinary meaning of burden of proof is burden of persuasion, and hold that Section 7(c) imposes a burden of persuasion, not simply a burden of production.

These benefits statutes and the Department of Labor's regulations interpreting them provide for a variety of presumptions favoring benefits claimants.

At the same time, the Administrative Procedure Act limits the Department's discretion in various respects.

One such important limitation is Section 7(c), the burden of proof section, which we conclude requires the benefits claimant to bear the burden of persuasion.

Justice Souter has filed a dissenting opinion which is joined by Justices Blackmun and Stevens.