Director, Office of Workers' Compensation Programs v. Greenwich Collieries, 512 U.S. 267 (1994)

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OCTOBER TERM, 1993

Syllabus

DIRECTOR, OFFICE OF WORKERS' COMPENSATION PROGRAMS, DEPARTMENT OF LABOR v. GREENWICH COLLIERIES et al.

certiorari to the united states court of appeals for the third circuit

No. 93-744. Argued April 25, 1994—Decided June 20, 1994*

In adjudicating separate benefits claims under the Black Lung Benefits

Act (BLBA) and the Longshore and Harbor Workers' Compensation Act (LHWCA), the Department of Labor Administrative Law Judges (ALJ's) both applied the Department's "true doubt" rule. This rule essentially shifts the burden of persuasion to the party opposing the claim so that when, as here, the evidence is evenly balanced, the benefits claimant wins. In both cases, the Department's Benefits Review Board affirmed the ALJ's decision to award benefits. However, the Court of Appeals vacated the Board's decision in the BLBA case, holding that the true doubt rule is inconsistent with the Department's own BLBA regulations, as well as with Mullins Coal Co. of Va. v. Director, Office of Workers' Compensation Programs, 484 U. S. 135. And, in the LHWCA case, the court reversed on the ground that the true doubt rule violates 7(c) of the Administrative Procedure Act (APA), which states that "[e]xcept as otherwise provided by statute, the proponent of a rule or order has the burden of proof."

Held: 1. Section 7(c)'s burden of proof provision applies to adjudications under the LHWCA and the BLBA, each of which contains a section incorporating the APA. Neither 33 U. S. C. 923(a), which relieves the Department of certain evidentiary and procedural requirements in LHWCA investigations and hearings, nor an ambiguous BLBA regulation providing that claimants be given the benefit of all reasonable doubt, is sufficient to overcome the presumption that adjudications are subject to the APA. See Brownell v. Tom We Shung, 352 U. S. 180, 185. Pp. 270-271. 2. The true doubt rule is not consistent with 7(c). Pp. 272-281. (a) An examination of Hill v. Smith, 260 U. S. 592, 594, and other relevant cases, as well as contemporary evidence treatises, demon-*Together with Director, Office of Workers' Compensation Programs, Department of Labor v. Maher Terminals, Inc., et al., also on certiorari to the same court (see this Court's Rule 12.2).

267

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