Supreme Court of the United States
Pittston Coal Group v. Sebben
December 6, 1988488 U.S. 105
Summary
Justice Scalia's majority opinion held that the Labor Department's interim black lung regulation violated 30 U. S. C. § 902(f)(2) by requiring ten years of coal mine employment to invoke a presumption available under the earlier HEW regulation upon direct proof of mining-related pneumoconiosis. The Court affirmed the Fourth Circuit's decision concerning timely appealed claims, without deciding the validity of Labor's additional rebuttal provisions. It reversed the Eighth Circuit's mandamus decision because the Secretary had no clear duty to reopen claims that had become final, and the published regulation supplied no basis for equitable tolling. Justice Stevens, joined by Chief Justice Rehnquist and Justices White and O'Connor, dissented from the statutory ruling, arguing that the Secretary's interpretation reasonably preserved medical criteria and deserved deference; he expressly agreed with the Court's mandamus analysis.
Holding
- Validity of the interim Labor regulation's ten-year employment requirement.. The categorical ten-year employment requirement violated § 902(f)(2), which required affirmative criteria for invoking the presumption of entitlement no more restrictive than those under the interim HEW regulation.
- Mandamus to reopen final benefits determinations.. Mandamus was unavailable because the claimants failed to establish a clear nondiscretionary duty to reopen their final determinations.
- Equitable tolling based on the unlawful regulation.. The circumstances did not justify equitable tolling, even assuming that tolling was available under the governing review provisions.
Docket 87-821
Cited authorities
- 20 C.F.R. §§ 727.203
- 20 C.F.R. §§ 410.401-410.476
- 20 C.F.R. §§ 410.422-410.426
- 30 U. S. C. 932(a)
- 30 U.S.C. § 902
- 20 C.F.R. § 410.490
- Pub. L. 91-173, 83
- 20 C.F.R. §§ 410.401-410.476