Director, Office of Workers' Compensation Programs v. Greenwich Collieries, 512 U.S. 267, 31 (1994)

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Cite as: 512 U. S. 267 (1994)

Souter, J., dissenting

cases conflicts with 20 CFR § 718.403 (1993), a Department of Labor regulation providing that "[e]xcept as provided in this subchapter, the burden of proving a fact alleged in connection with any provision of this part shall rest with the party making such allegation." But the phrase "burden of proving," like its cognate, "burden of proof," is susceptible of two meanings, including the meaning given by the agency interpretation, as imposing only the burden of producing evidence. The Department of Labor is entitled to "substantial deference" in the interpretation of its own regulations, and the agency's interpretation need only be reasonable in light of the regulations' text and purpose, Martin v. Occupational Safety and Health Review Comm'n, 499 U. S. 144, 150-151 (1991); accord, Bowles v. Seminole Rock & Sand Co., 325 U. S. 410, 414 (1945). The agency's interpretation of its regulation is surely reasonable here, given our own prior interpretation of "burden of proof" as referring only to production.

The Department of Labor's decision in the true doubt rule, to assign the burden of persuasion to the employer in cases involving harms to workers in the longshore and coal mining industries, is thus permissible and free from conflict with § 7(c) of the APA. I would sustain the Department's rule, and accordingly offer this respectful dissent.

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