Tuesday, May 21, 2013

Pauley v. BethEnergy Mines, Inc. case brief

Pauley v. BethEnergy Mines, Inc. case brief
501 U.S. 680, 111 S. Ct. 2524, 115 L. Ed. 2d 604 (1991)

CASE SYNOPSIS: Petitioners, miner and mining companies, sought a writ of certiorari to review the statutory interpretation by the United States Courts of Appeals for the Third and Fourth Circuits of interim regulations adopted by respondent, Department of Labor, to better address claims for black lung benefits.

FACTS: Petitioners, miner and mining companies, challenged the lower courts' interpretation of interim regulations, 20 C.F.R. § 727.203(b)(3), (4), adopted by respondent, Department of Labor, to better handle the number of claims for back lung benefits. Petitioners sought a writ of certiorari and claimed that the regulations were too restrictive and therefore were invalid. The court granted certiorari and consolidated the claims. The court affirmed the denial of benefits in the first case and reversed and remanded on the other two cases. The court held that the regulations were not inconsistent with the agency's statutory authority under 30 U.S.C.S. § 902(f)(2). The court concluded that given advances in medical technology and agency deference to the Secretary of Labor's interpretation of the regulations, the regulations that permitted presumptions of entitlement to be rebutted were proper. Presumptions of entitlement were allowed to be rebutted with evidence that demonstrated that an applicant did not have pneumoconiosis or that the miner's disability did not arise out of coal mine employment.

CONCLUSION: The court granted certiorari, consolidated three cases, affirmed the first case and reversed and remanded the other two cases, as it was not unreasonable or inconsistent with enabling legislation to have promulgated interim regulations that permitted a presumption of entitlement to black lung benefits to be rebutted.

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