Martin v. Occupational Safety and Health Review Commission

The Occupational Safety and Health Act of 1970 (the act) was enacted to protect the health and safety of employees in their workplaces. The secretary of labor (the secretary) (plaintiff) was given rulemaking and enforcement powers to administer the act, and the Occupational Health and Safety Review Commission (the commission) (defendant) was charged with adjudicating issues that arose under the act. The secretary issued citations for violations of the act, and administrative-law judges and the commission held evidentiary hearings to affirm, modify, or reverse the secretary’s citations. Using her rulemaking powers, the secretary established maximum coke-oven emission levels and required employees to use respirators under certain conditions. The secretary issued a citation against CF & I Steel Corporation (the steel company) for giving its employees respirators that did not fit tightly enough to protect them from coke-oven emissions. The secretary reasoned that the steel company’s actions violated a regulation that required the company to train its employees to properly use respirators. The administrative-law judge upheld the secretary’s citation. The commission reversed the citation, finding that the steel company’s actions had not violated the relevant regulation. The commission explained that the regulation cited by the secretary did not require an employer to ensure that its employees’ respirators fit properly. The secretary petitioned the court of appeals for review. The court of appeals held that the commission’s interpretation of the regulation should be deferred to, and it affirmed the commission. The secretary appealed, arguing that the court of appeals should have deferred to her interpretation of the regulation. The United States Supreme Court granted certiorari.