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American Textile Manufacturers Institute v. Donovan

452 U.S. 490, 101 S.Ct. 2478, 69 L.Ed.2d 185 (1981)

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American Textile Manufacturers Institute v. Donovan

United States Supreme Court

452 U.S. 490, 101 S.Ct. 2478, 69 L.Ed.2d 185 (1981)

Facts

Secretary of Labor Raymond Donovan (defendant), acting through the Occupational Safety and Health Administration (OSHA), promulgated a new standard to limit workplace exposure to cotton dust. American Textile Manufacturers Institute and other representatives of the cotton industry (the business interests) (defendants) brought suit to challenge the validity of the standard. The business interests argued that OSHA was required to conduct a cost-benefit analysis and demonstrate a reasonable relationship between the costs and benefits of the standard, but Donovan argued that only a feasibility analysis was necessary. Donovan’s argument reflected the statutory language of the Occupational Safety and Health Act, which charges OSHA to issue standards that protect the health of employees “to the extent feasible.” The business interests also challenged a regulatory provision that required employers to guarantee no loss in wages for employees who were transferred to other positions due to the employees’ inability to wear respirators. The United States Court of Appeals upheld the challenged provisions. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Brennan, J.)

Dissent (Rehnquist, J.)

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