Director, Office of Workers' Compensation Programs v. Greenwich Collieries
Headline: Court strikes down the Department of Labor’s 'true doubt' rule for benefit claims, holding claimants lose when evidence is evenly balanced and restoring the claimant’s burden of persuasion.
Holding: The Court held that the Department of Labor’s 'true doubt' rule violates the APA because 'burden of proof' means burden of persuasion, so claimants do not win when evidence is evenly balanced.
- Stops automatic benefit awards when evidence is evenly balanced.
- Requires claimants to persuade the decisionmaker, not rely on tie-breaking.
- Limits the Labor Department’s ability to shift persuasion burden by regulation.
Summary
Background
Andrew Ondecko, a coal miner of 31 years, and Michael Santoro’s widow each sought disability or survivor benefits under federal benefit laws. The Department of Labor adjudicators applied a "true doubt" rule that awards benefits when the evidence for and against a claim is evenly balanced, effectively shifting the burden of persuasion to the party opposing benefits. In Ondecko’s case an ALJ found pneumoconiosis, disability, and work-related causation relying partly on a statutory presumption; the Board affirmed but the Court of Appeals reversed. In Santoro’s case an ALJ and the Board awarded benefits after finding evidence equally probative; the Court of Appeals again reversed. The Supreme Court agreed to decide whether the rule fits the Administrative Procedure Act’s requirement that the proponent of an order bear the burden of proof.
Reasoning
The Court read the APA’s phrase “burden of proof” in light of historical usage and prior decisions and concluded it means the burden of persuasion. It rejected the Department’s arguments that the longshore and black-lung statutes or agency regulations displace §7(c). Because the true doubt rule makes claimants win when evidence is evenly balanced — thereby placing the burden of persuasion on the opponent — the Court held the rule conflicts with §7(c). The Court therefore struck down the true doubt rule and affirmed the Court of Appeals’ rulings.
Real world impact
Claimants for longshore and black-lung benefits can no longer rely on an agency rule that awards benefits when evidence is evenly balanced; claimants remain responsible for persuading the factfinder. The decision was made under §7(c), so it does not resolve every regulatory disagreement about presumptions or evidentiary rules.
Dissents or concurrances
Justice Souter dissented, arguing the rule had long administrative and judicial history and fit the remedial purposes of the benefits statutes; he would have upheld the rule.
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