Director, Office of Workers' Compensation Programs v. Greenwich Collieries

An administrative law judge relied on the Department of Labor's true doubt rule — which placed the burden of persuasion on the party opposing a benefits claim rather than on the claimant — to award workers' compensation benefits to Santoro's widow, and the Benefits Review Board affirmed; the court of appeals vacated, finding the true doubt rule conflicted with APA § 7(c), which places the burden of proof on the proponent of a rule or order.