Dole v. United Steelworkers of America

The United States Department of Labor (DOL) (defendant), a federal agency, issued a rule that contained a disclosure requirement. This disclosure requirement obligated manufacturers to inform employees about workplace hazards. The federal Office of Management and Budget (OMB) administered the implementation of the Paperwork Reduction Act of 1980 (Act). The Act required the OMB to review and approve all information-collection requests, sometimes known as ICRs. Based on the OMB’s interpretation of the Act, the DOL’s disclosure requirement was an information-collection request. Accordingly, the OMB reviewed the DOL’s disclosure requirement and ultimately disapproved it. The DOL noted it disagreed with the OMB, but the DOL then withdrew the disclosure requirement from the rule. A labor union, the United Steelworkers of America (Steelworkers) (plaintiff), sued the DOL. The Steelworkers contended that the disclosure requirement was not an information-collection request within the meaning of the Act. If the disclosure requirement was not an information-collection request, then the OMB's disapproval of the disclosure requirement provided no grounds for the DOL's withdrawal of that requirement. Accordingly, the Steelworkers argued that the DOL should not have withdrawn the requirement that manufacturers warn their employees about workplace hazards. The court of appeals found that the DOL’s disclosure requirement was not an information-collection request as defined by the Act. Therefore, the OMB lacked authority to review the DOL’s disclosure requirement, and the appellate court ruled for the Steelworkers. The United States Supreme Court granted certiorari to determine the Act’s scope.