Pauley v. Bethenergy Mines, Inc.
United States Supreme Court
501 U.S. 680 (1991)
When administration of federal black-lung disability benefits transferred from HEW to the Department of Labor (DOL), the transferring statute required DOL's regulations to be no more restrictive than HEW's had been; DOL's new regulations allowed employers like Bethenergy (defendant) to rebut a miner's entitlement to benefits by showing the disability was unrelated to coal mining, a rebuttal ground HEW's regulations had not included, though DOL characterized this addition as consistent with the no-more-restrictive requirement. Miner Pauley (plaintiff) challenged Bethenergy's reliance on this new rebuttal ground, and the case reached the Supreme Court.
Whether a federal agency's statutory interpretation is entitled to judicial deference where the agency is responsible for administering a complex statute and its interpretation of that statute is reasonable.