Citation. Pauley v. Bethenergy Mines, 501 U.S. 680, 111 S. Ct. 2524, 115 L. Ed. 2d 604, 1991 U.S. LEXIS 3638, 59 U.S.L.W. 4778, 91 Cal. Daily Op. Service 4811, 91 Daily Journal DAR 7442 (U.S. June 24, 1991)
Brief Fact Summary. Congress created the black lung benefits program, to be administered first by Social Security Administration (SSA), under the then-existing Department of Health, Education and Welfare (HEW), and later by the Department of Labor (DOL). Congress authorized these Departments to adopt interim regulations governing the adjudication of claims, but constrained the DOL from passing more strict regulations than HEW. Two of the DOL’s rebuttal presumptions were challenged in this case.
Synopsis of Rule of Law. When Congress, through express delegation or the introduction of an interpretive gap in the statutory structure, has delegated policy-making authority to an administrative agency, the extent of judicial review is limited. If deference is thus owed to the agency’s determination, the Court must still decide if the agency’s position is reasonable.
Issue. Were the Secretary of Labor’s rebuttable presumptions reasonable?
Held. Yes. The Court upheld DOL’s rebuttable presumptions (and interpretation of the statute) as reasonable. The BLBRA was a highly complex and technical regulatory program, under which Congress specifically constrained the Secretary of Labor from making criteria more restrictive than HEW’s. Since Congress expressly delegated authority to the agencies, the extent of judicial review was limited, and deference was owed to the DOL. The Secretary of Labor’s interpretation of the complex regulatory structure was reasonable. Dissent. The regulatory language was complex, but not ambiguous, and Chevron deference was not required. Concurrence. None.
Discussion. The Court upheld DOL’s presumptions based on its finding that they were “reasonable.”