In the case of Director, Office of Workers' Compensation Programs, Department of Labor v. Greenwich Collieries (1993), the U.S. Supreme Court ruled on a matter concerning workers' compensation law and administrative procedure. The issue at hand was whether or not it was constitutional for the "true doubt" rule to be applied in cases where there is equal evidence for both sides in a dispute over benefits under the Black Lung Benefits Act. This rule stated that if evidence from both parties were equally balanced, then any doubts would be resolved in favor of coal miners claiming black lung disease caused by their work environment. The court held that this true-doubt rule violated the Administrative Procedure Act's requirement that claimants must prove their entitlements by a preponderance of evidence - meaning they need more convincing proof than their opponents to win their case. Therefore, it concluded that applying such a standard unfairly shifted burdens onto employers and insurance carriers who are defending against these claims.

In the dissenting opinion of the case Director, Office of Workers' Compensation Programs, Department of Labor v. Greenwich Collieries (1993), Justice Blackmun argued that the majority misinterpreted and misapplied Section 7(c) of the Administrative Procedure Act (APA). He believed that this section should not be interpreted to mean a party must prove its claim by a preponderance of evidence but rather it only needs to show its claim is as likely true as not. Furthermore, he disagreed with their interpretation that "burden of proof" includes both burden production and persuasion; instead he asserted APA's legislative history indicates they are separate concepts. Lastly, he criticized their decision for being inconsistent with Congress’s intent in passing black lung benefits legislation which was meant to provide broad coverage for miners. By making it harder for miners to qualify for these benefits through requiring them meet higher standard proof than what had been previously required under law would undermine this purpose.