## Facts

- Congress enacted a federal benefits program for coal miners disabled by pneumoconiosis (“black lung”) and certain survivors under Title IV of the Federal Coal Mine Health and Safety Act of 1969, as amended by the Black Lung Benefits Act of 1972.
- The statutory scheme divided payment responsibility among the federal government and coal mine operators based largely on claim-filing dates and transition rules:
  - Earlier claims were federally paid.
  - Later claims were paid by mine operators through a system incorporating federal processing when state plans were absent or unapproved.
- For certain claims, operators were required to pay benefits after January 1, 1974, including for miners whose coal-mine employment may have ended before the relevant legislation.
- The Act defined “total disability” in functional terms tied to inability to perform comparable gainful work due to pneumoconiosis.
- The Act included evidentiary presumptions to ease proof of entitlement, including an irrebuttable presumption that “complicated pneumoconiosis” conclusively established total disability (or, if the miner was deceased, death due to the disease).
- Coal mine operators filed suit in federal court challenging multiple provisions as unconstitutional under the Fifth Amendment, including retroactive operator liability and statutory presumptions affecting proof of disability and causation.
- A three-judge district court upheld the Act on its face except for two provisions related to determining total disability from pneumoconiosis; both sides appealed.

## Issues

1. Whether the Fifth Amendment’s Due Process Clause prohibits Congress from imposing operator liability, effective January 1, 1974, for black-lung disabilities and deaths attributable to mine employment that occurred before enactment.
2. Whether the Act’s evidentiary presumptions (including the irrebuttable presumption for complicated pneumoconiosis) violate due process because they are irrational or deny a fair opportunity to contest liability.
3. Whether the overall allocation and timing of liability among the federal government and mine operators is arbitrary or irrational under due process standards applicable to economic legislation.

## Decision

- The Supreme Court upheld the Act’s retroactive imposition of liability on coal mine operators for benefits payable after January 1, 1974, including benefits connected to prior employment that predated the statute.
- The Court sustained the central benefit-and-liability framework against due process attacks, applying a deferential rational-basis standard to economic and social welfare legislation.
- The Court upheld most of the statutory presumptions, including the irrebuttable presumption tied to complicated pneumoconiosis, as sufficiently grounded in medical reality and legislative judgment.
- The Court reversed the district court to the extent it had invalidated portions of the statute and affirmed the statute’s constitutionality in broad outline.

## Legal Principles

- Economic and social welfare legislation is reviewed under rational-basis scrutiny; it is constitutional if Congress acted rationally in furthering a legitimate purpose.
- Legislation that readjusts rights and burdens is not unconstitutional merely because it upsets settled expectations or imposes new liabilities based on past conduct; retroactivity violates due process only if it is arbitrary and irrational.
- Congress may impose retroactive financial responsibility as a cost-spreading measure to address long-latency occupational harms by assigning costs to those who profited from the underlying labor.
- Statutory presumptions in benefits schemes satisfy due process if there is a rational connection between the proven fact and the presumed fact and, where labeled rebuttable, the opposing party has a meaningful opportunity to present relevant rebuttal evidence.
- An irrebuttable presumption may be sustained where Congress could rationally conclude that the established medical condition reliably signifies the statutory disability or cause of death.

## Conclusion

The Court held that Congress could rationally impose retroactive black-lung benefit liability on coal mine operators and could employ medically grounded presumptions to facilitate claims, because the scheme was a permissible, nonpunitive cost-spreading response to an occupational disease and was not arbitrary or irrational under the Fifth Amendment.


Usery v. Turner Elkhorn Mining Co., 428 U.S. 1 (1976)