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Administrative Law Keyed to Aman
Director, Office of Workers’ Compensation Programs v. Greenwich Collieries
Citation:
512 U.S. 267 (1994)Facts
The Supreme Court reviewed two separate cases. 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 the disease resulted from coal mine employment. In making these determinations, the ALJ relied on the true doubt rule, which resolves evenly balanced evidence in favor of the claimant. In the second case, Michael Santoro’s widow filed a claim under the Longshore and Harbor Workers’ Compensation Act after Santoro suffered a work-related injury and subsequently died from nerve cancer. The ALJ found the evidence equally probative and, applying the true doubt rule, awarded benefits. In both cases, the Benefits Review Board affirmed, but the Court of Appeals for the Third Circuit reversed, holding that the true doubt rule was inconsistent with § 7(c) of the Administrative Procedure Act.
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