The U.S. Supreme Court case Mullins Coal Co., Inc. of Virginia, et al. v. Director, Office of Workers' Compensation Programs, United States Department of Labor, et al., 1987 revolved around the Black Lung Benefits Act (BLBA). The BLBA provides benefits to coal miners who are totally disabled due to pneumoconiosis ("black lung disease") arising from their employment in or around the nation's coal mines. In this case, a group of coal companies challenged an amendment made by Congress that presumed certain miners were eligible for these benefits unless it could be proven otherwise by the employer - essentially shifting the burden of proof onto them rather than on claimants as was previously required under common law rules relating to workers’ compensation claims. The court upheld this presumption and ruled against Mullins Coal Company and other petitioners arguing that they should not bear this burden because it violated their rights under Due Process Clause and Administrative Procedure Act (APA). The court found no violation stating that such presumptions have long been used in social welfare legislation where proving causation can be difficult for claimants.

In the dissenting opinion for Mullins Coal Co., Inc. of Virginia, et al. v. Director, Office of Workers' Compensation Programs, United States Department of Labor, et al., Justice O'Connor disagreed with the majority's interpretation of the Black Lung Benefits Act (BLBA). She argued that it was not Congress's intent to make coal mine operators liable for benefits to miners who were totally disabled due to pneumoconiosis but had left their employment before 1970 when BLBA came into effect. According to her view, such an interpretation would unfairly impose retroactive liability on employers and could potentially bankrupt them. Furthermore, she contended that this ruling contradicted previous court decisions which held that laws should not be applied retroactively unless explicitly stated by Congress.