Usery, Secretary of Labor, et al. v. Turner Elkhorn Mining Co. et al.
428 U.S. 1 (1976)
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Rule of Law:
Legislation adjusting the burdens and benefits of economic life, including the retroactive imposition of liability on employers for occupational diseases, does not violate the Due Process Clause of the Fifth Amendment so long as it is a rational measure to spread the costs of employees' disabilities to the industry that profited from their labor.
Facts:
- Coal miners developed a severe, irreversible, and often crippling respiratory disease called pneumoconiosis, or "black lung disease," from long-term inhalation of coal dust.
- The disease is progressive, and its symptoms often become apparent only after a miner has already left employment in the coal mines.
- For many years, state workers' compensation programs were insufficient to provide benefits for miners afflicted with pneumoconiosis.
- In response, Congress passed the Federal Coal Mine Health and Safety Act of 1969, later amended by the Black Lung Benefits Act of 1972.
- The amended Act required coal mine operators to pay benefits to miners who became totally disabled from pneumoconiosis arising out of their employment.
- This liability extended to miners who had terminated their employment with the operators before the Act was passed.
- The Act also established several statutory presumptions to assist miners in proving their claims, such as presuming a miner with 10 years of experience contracted the disease from their employment.
Procedural Posture:
- Twenty-two coal mine operators (Operators) sued the Secretary of Labor and the Secretary of Health, Education, and Welfare in the U.S. District Court for the Eastern District of Kentucky, a federal trial court.
- The Operators sought a declaratory judgment and an injunction to prevent the enforcement of certain provisions of the amended Federal Coal Mine Health and Safety Act, arguing they were unconstitutional.
- A special three-judge District Court was convened to hear the case.
- On cross-motions for summary judgment, the District Court found most of the Act constitutional, but held that two provisions were unconstitutional: the irrebuttable presumption of total disability in § 411(c)(3) and the limitation on rebuttal evidence in § 411(c)(4).
- The District Court enjoined the Secretary of Labor from applying these two provisions.
- Both the Operators (appellants in No. 74-1316) and the Federal Parties (appellants in No. 74-1302) filed cross-appeals directly with the United States Supreme Court.
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Issue:
Does the Federal Coal Mine Health and Safety Act, as amended, which imposes liability on coal mine operators for former employees' black lung disease and establishes certain evidentiary presumptions to aid claimants, violate the Due Process Clause of the Fifth Amendment?
Opinions:
Majority - Mr. Justice Marshall
No, the Federal Coal Mine Health and Safety Act does not violate the Due Process Clause. Retroactive economic legislation is constitutional if it serves a rational legislative purpose. Imposing liability for past disabilities is justified as a rational measure to spread the costs of the employees' disabilities to those who have profited from their labor—the operators and coal consumers. The Act's evidentiary presumptions are also constitutional because there is a rational connection between the fact proved (e.g., 10 years of mine work) and the ultimate fact presumed (e.g., the disease arose from that work). Similarly, Congress's decision to treat a diagnosis of complicated pneumoconiosis as conclusive proof of total disability is a permissible way to define eligibility for benefits, not an unconstitutional irrebuttable presumption.
Concurring-in-part-and-dissenting-in-part - Mr. Justice Powell
No, the Act is not unconstitutional on this record, but the majority's reasoning is questionable. While concurring in the judgment, the rationality of imposing retroactive liability as a cost-spreading device is highly speculative. It is unlikely that operators earned 'excess profits' in the past or that they can now effectively pass these retroactive costs on to consumers in a competitive market, especially given the declining size of the industry. However, economic legislation carries a strong presumption of constitutionality, and the Operators failed to make the necessary factual showing on summary judgment to overcome that presumption.
Concurring-in-part-and-dissenting-in-part - Mr. Justice Stewart
No, the Act's provisions are constitutional, but the majority errs in its statutory interpretation of the limitation on rebuttal evidence in § 411(c)(4). The majority avoids a constitutional question by incorrectly concluding that this limitation does not apply to operators. A proper reading of the statute, particularly § 430, shows the limitation was intended to apply to operators in Part C proceedings. Even so, this limitation is constitutional, as it is part of Congress's rational scheme to allocate the burden of proof in these claims. I would therefore reverse the District Court's ruling on this point rather than vacating it.
Analysis:
This case firmly establishes the constitutionality of retroactive liability in the context of economic and social welfare legislation, provided it meets the rational basis test. It affirms Congress's broad power to address latent occupational diseases by shifting the economic burden to the industry responsible, even for conduct that occurred before the liability was established. The Court's deference to Congress's use of evidentiary presumptions and its framework for defining disability solidifies a legislative model for future compensation schemes targeting long-latency harms in other industries. The decision significantly limits due process challenges to such regulatory efforts, making it harder for businesses to defeat them on grounds of retroactivity or settled expectations.
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