Pittston Coal Group v. Sebben

Summary

The Court held that the term “criteria” in 30 U.S.C. §902(f)(2) includes all standards, not merely medical ones, so the Secretary of Labor’s interim regulation is impermissibly more restrictive and invalid. It also held that mandamus cannot compel the Secretary to reopen final black‑lung determinations because no clear nondiscretionary duty exists. The decision affirms the Fourth Circuit, reverses the Eighth Circuit, and remands with instructions to dismiss the mandamus petition. Justice Stevens’ dissent argues that “criteria” refers only to medical criteria and that the Secretary’s regulation should be upheld.