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Pauley v. Bethenergy Mines, Inc.
United States Supreme Court
501 U.S. 680 (1991)
A federal statutory program provided benefits for coal miners disabled by black-lung disease. Originally, the program was administered by the federal Department of Health, Education, and Welfare (HEW). The statute that transferred the program from the HEW to the federal Department of Labor (DOL) specified that the DOL's program regulations must be no more restrictive than the HEW's regulations. Both the HEW and the DOL allowed an employer to rebut the presumption that an employee was entitled to benefits. However, unlike the HEW, the DOL allowed a rebuttal based on an employer's showing that the employee's disability was not connected with coal mining. The DOL interpreted this new basis for rebuttal as no more restrictive than the HEW's regulations and, therefore, in compliance with the statute. Bethenergy Mines, Inc. (Bethenergy) (defendant) relied on the DOL's interpretation to contend that Bethenergy's employee, John Pauley (plaintiff), was not entitled to program benefits because Pauley's disability was not connected with coal mining. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Blackmun, J.)
Dissent (Scalia, J.)
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