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Administrative Law Keyed to Seamon
Director, Office of Workers’ Compensation Programs v. Greenwich Collieries
Citation:
512 U.S. 267 (1994)Facts
The case consolidated two separate claims. In the first, Andrew Ondecko applied for disability benefits under the Black Lung Benefits Act after working as a coal miner for 31 years. The Administrative Law Judge determined Ondecko had pneumoconiosis, was totally disabled by it, and that it resulted from coal mine employment, relying on the true doubt rule to resolve evidentiary conflicts. In the second case, Michael Santoro suffered a work-related injury while employed by Maher Terminals and was later diagnosed with nerve cancer, dying shortly thereafter. His widow filed a claim under the Longshore and Harbor Workers’ Compensation Act. The ALJ found the evidence equally probative and, using the true doubt rule, awarded benefits. In both cases, the Benefits Review Board affirmed, but the Third Circuit reversed, holding that the true doubt rule violated § 7(c) of the Administrative Procedure Act by improperly shifting the burden of persuasion to the party opposing benefits.
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