Director, Office of Workers’ Compensation Programs, Department of Labor v. Greenwich Collieries

Summary

Justice O’Connor’s majority opinion held that § 7(c) of the Administrative Procedure Act applies to the benefits adjudications at issue and places the burden of persuasion, not merely production, on the party seeking benefits. The Department of Labor’s true doubt rule therefore violates the APA by awarding benefits when the evidence is evenly balanced. The Court affirmed both Third Circuit judgments and rejected Transportation Management’s contrary interpretation of § 7(c), while preserving that decision’s holding concerning an employer’s affirmative defense. Justice Souter dissented, joined by Justices Blackmun and Stevens. He argued that the statutory language, legislative history, and precedent establish only a burden of production, leaving agencies discretion to allocate the burden of persuasion, and would have sustained the true doubt rule.