Director, Office of Workers' Compensation Programs v. Greenwich Collieries, 512 U.S. 267, 2 (1994)

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268

DIRECTOR, OFFICE OF WORKERS' COMPENSATION PROGRAMS v. GREENWICH COLLIERIES

Syllabus

strates that, in 1946, the year the APA was enacted, the ordinary meaning of § 7(c)'s "burden of proof" phrase was burden of persuasion (i. e., the obligation to persuade the trier of fact of the truth of a proposition), not simply burden of production (i. e., the obligation to come forward with evidence to support a claim). This Court presumes that Congress intended the phrase to have the meaning generally accepted in the legal community at the time of enactment. See, e. g., Holmes v. Securities Investor Protection Corporation, 503 U. S. 258, 268. Because the true doubt rule places the burden of persuasion on the party opposing a benefits award, it violates § 7(c)'s requirement that that burden rest with the party seeking the award. Pp. 272-276. (b) In light of the foregoing, the cursory conclusion set forth in NLRB v. Transportation Management Corp., 462 U. S. 393, 404, n. 7— in which the Court stated that § 7(c) determines only the burden of going forward, not the burden of persuasion—cannot withstand scrutiny. Pp. 276-278. (c) The Department's reliance on imprecise and marginally relevant passages from the APA's legislative history is unavailing. Pp. 278-280. (d) The true doubt rule runs afoul of the APA's goal of greater uniformity of procedure and standardization of administrative practice among the diverse federal agencies, for under the Department's reading each agency would be free to decide who bears the burden of persuasion. Pp. 280-281. 3. Because these cases are decided on the basis of § 7(c), this Court need not address the Court of Appeals' holding that the true doubt rule conflicts with BLBA regulations and Mullins Coal. P. 281.

990 F. 2d 730 (first case) and 992 F. 2d 1277 (second case), affirmed.

O'Connor, J., delivered the opinion of the Court, in which Rehnquist, C. J., and Scalia, Kennedy, Thomas, and Ginsburg, JJ., joined. Souter, J., filed a dissenting opinion, in which Blackmun and Stevens, JJ., joined, post, p. 281.

Edward C. DuMont argued the cause for petitioner in both cases. With him on the briefs were Solicitor General Days, Deputy Solicitor General Kneedler, Steven J. Mandel, and Edward D. Sieger.

Mark E. Solomons argued the cause for respondents in both cases. With him on the brief for respondent Greenwich Collieries were Laura Metcoff Klaus and John J. Bagnato. Joseph T. Stearns filed a brief for respondent Maher Termi-

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