Pauley v. Bethenergy Mines, Inc.

501 U.S. 680 (1991)

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Nature of the Case

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Facts

Congress created a black lung benefits program to provide compensation for disability to miners due to pneumoconiosis arising out of coal mine employment. The Department of Health, Education, and Welfare (HEW) managed the program, which was later was transferred to the Department of Labor (DOL). On the transfer, Congress constrained DOL in that its regulations 'shall not be more restrictive than' HEW's. HEW regulations permitted a rebuttable statutory presumption of eligibility for benefits upon introduction by the claimant of specified medical evidence and a demonstration that the it arose out of coal mine employment. SSA could rebut the presumption by two methods. DOL regulations set forth four rebuttal provisions. The first two were the same as HEW regulations. The third permits rebuttal upon a showing that the miner's disability did not arise in whole or in part out of coal mine employment and the fourth authorizes rebuttal with evidence demonstrating that the miner does not have pneumoconiosis. Bethenergy (D) relied on the DOL regulations to claim that Pauley (P) was not entitled to benefits by using the third rebuttal. The Court of Appeals for the Third Circuit concluded that the DOL interim regulations were not more restrictive. In Clinchfield Coal Co. v. Director, Office of Workers' Compensation Programs, Dept. of Labor, and Consolidation Coal Co. v. Director, Office of Workers' Compensation Programs, Dept. of Labor, the Court of Appeals for the Fourth Circuit struck down the DOL interim regulations. The Fourth Circuit determined that the third and fourth rebuttal methods 'permit rebuttal of more elements of entitlement to benefits than do the interim HEW regulations,' because the HEW regulations permit rebuttal 'solely through attacks on the element of total disability,' while the DOL regulations 'allow the consideration of evidence disputing both the presence of pneumoconiosis and the connection between total disability and coal mine employment.' Accordingly, the court concluded that the DOL interim regulations were more restrictive. The Supreme Court granted certiorari.