In the case of Director, Office of Workers' Compensation Programs, United States Department of Labor v. Rasmussen et al., 1978, the Supreme Court ruled on whether a widow could claim benefits under the Federal Coal Mine Health and Safety Act (FCMHSA) for her husband's death due to pneumoconiosis or "black lung disease". The court held that even though Mr. Rasmussen had not filed a claim before his death as required by FCMHSA, Mrs. Rasmussen was still eligible to receive survivor benefits because she met all other requirements set forth in the act. This decision clarified that while filing a claim is necessary for miners seeking disability benefits during their lifetime, it does not preclude survivors from receiving compensation after their passing if they can prove that black lung disease contributed significantly to their loved one’s demise.

In the dissenting opinion for Director, Office of Workers' Compensation Programs, United States Department of Labor v. Rasmussen et al., Justice Rehnquist disagreed with the majority's interpretation that a widow is entitled to death benefits under the Longshoremen's and Harbor Workers' Compensation Act even if her husband’s work-related injury was not a substantial contributing cause of his death. He argued that this interpretation contradicted Congress’ intent when it enacted amendments in 1972 which required an employee’s disability or death to be "not less than" caused by employment conditions. The justice believed that these words clearly indicated Congress intended for there to be a significant causal connection between workplace injuries and subsequent disabilities or deaths before compensation could be awarded. Therefore, he concluded that Mrs. Rasmussen should not have been eligible for benefits because her husband's work-related injury did not significantly contribute to his eventual demise from heart disease.