United States Department of Labor v. Triplett
Upheld Labor Department’s fee-approval system for black lung claims, reversing a state court and allowing federal rules to continue restricting attorneys’ unapproved contingency fees and payments.
Holding
The Court reversed the West Virginia high court and held that the Department of Labor's fee-approval rules under the Black Lung Benefits Act do not violate the Fifth Amendment because the record did not show claimants lacked access to counsel.
Real-world impact
- Allows the Department of Labor to continue approving attorney fees before lawyers collect payment.
- Limits lawyers’ use of private contingency contracts without agency approval.
- Requires stronger factual records to win constitutional challenges to fee rules.
Topics
Summary
Background
George Triplett, a private lawyer, accepted 25% contingency fees from people seeking federal black lung disability benefits without getting the Department of Labor's approval. A state bar committee disciplined him, and the West Virginia Supreme Court of Appeals held the Department’s fee-approval system unconstitutional, saying it denied claimants access to counsel. The Department intervened, supplemented the record, and the dispute reached this Court.
Reasoning
The Court asked whether the fee rules made lawyers unavailable and whether that unavailability was caused by the Department’s system. It required concrete proof on both points. The Court found the state court relied mainly on anecdotal lawyer statements and sparse affidavits, while the Department produced non‑anecdotal data showing high representation rates at the administrative level. The Court concluded the record did not prove that the fee regulations deprived claimants of counsel or violated due process, and it reversed the state court’s judgment.
Real world impact
The decision lets the Department continue to require agency approval of attorney fees and to award
Opinions in this case
- 1.Opinion 9431960
- 2.Opinion 9431961
- 3.Opinion 112399
Questions, answered
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