## Facts

- Congress created a federal black lung benefits program for miners disabled by pneumoconiosis arising from coal mine work and for eligible survivors.
- Claims administration was split: earlier claims were handled by the Social Security Administration under HEW; later claims were handled by the Department of Labor (DOL), with operators generally paying benefits.
- Congress authorized interim regulations for each agency but required DOL’s interim regulations to be “not more restrictive than” HEW’s.
- HEW’s interim rule allowed a presumption of eligibility based on specified medical evidence plus a showing the impairment arose from coal mine employment; HEW’s presumption could be rebutted through limited routes stated in its rule.
- DOL’s interim rule likewise created a presumption of eligibility but listed four rebuttal methods, including two additional provisions allowing rebuttal by showing (a) disability or death did not arise in whole or in part from coal mine employment, or (b) the miner did not have pneumoconiosis.
- Federal courts split on whether DOL’s third and fourth rebuttal provisions violated the “not more restrictive than” constraint; the Supreme Court granted review to resolve the conflict.

## Issues

1. Whether DOL’s third and fourth rebuttal provisions make its interim black lung regulations “more restrictive than” HEW’s interim regulations in violation of Congress’s directive.
2. Whether, and to what extent, courts must defer to the Secretary of Labor’s interpretation of the statutory “not more restrictive than” requirement and the relationship between the HEW and DOL interim rules.

## Decision

- The Court held that DOL’s third and fourth rebuttal provisions do not render DOL’s interim regulations “more restrictive than” HEW’s.
- The Court deferred to the Secretary of Labor’s reasonable interpretation of the statute and regulatory scheme under Chevron principles.
- The Court affirmed the Third Circuit judgment upholding DOL’s regulations and reversed the Fourth Circuit judgments invalidating them.

## Legal Principles

- When Congress leaves an interpretive gap in a complex regulatory statute, a court generally defers to an agency’s reasonable construction of the statute (Chevron deference).
- The “not more restrictive than” constraint is assessed by comparing the regulations in operation and as a whole, not by counting the number of rebuttal routes in isolation.
- HEW’s interim framework, read together with its cross-referenced causation provisions, could accommodate rebuttal evidence negating causation and, functionally, evidence disputing the existence of pneumoconiosis; DOL’s explicit rebuttal provisions therefore were not necessarily harsher than HEW’s.
- An agency may permissibly make explicit rebuttal mechanisms that are consistent with the structure and effect of the predecessor framework, so long as the resulting regime is not more restrictive overall.

## Conclusion

The Supreme Court upheld DOL’s additional interim rebuttal provisions for black lung claims as consistent with Congress’s “not more restrictive than” directive and deferred to the Secretary of Labor’s reasonable reading of the intertwined HEW and DOL regulatory schemes.


Pauley v. BethEnergy Mines, Inc., 501 U.S. 680 (1991)