In the 1990 case of Harriet Pauley, survivor of John C. Pauley v. BethEnergy Mines, Inc., et al., the U.S. Supreme Court ruled in favor of BethEnergy Mines and against Mrs. Pauley who was seeking benefits under the Black Lung Benefits Act after her husband's death from black lung disease (pneumoconiosis). The court held that a regulation by Department of Labor allowing coal mine operators to rebut claims for benefits by showing that a deceased miner was not totally disabled due to pneumoconiosis at time of death did not violate due process rights or exceed statutory authority granted by Congress under Black Lung Benefits Act. This decision effectively made it more difficult for survivors to claim these types of benefits unless they could prove total disability directly caused by pneumoconiosis prior to their loved one’s passing.

In the dissenting opinion for Harriet Pauley v. BethEnergy Mines, Inc., Justice Blackmun argued that the majority's decision was inconsistent with Congress' intent when it enacted the Black Lung Benefits Act. He believed that by allowing coal companies to deny benefits based on a rebuttable presumption of disability due to pneumoconiosis, they were undermining the purpose of this legislation - which is to provide financial assistance and medical treatment for miners suffering from black lung disease. Furthermore, he criticized their interpretation of "total disability," stating that it should not be narrowly defined as an inability to perform any work at all but rather as a significant impairment in life activities caused by pneumoconiosis. In his view, this broader definition would better serve miners who are still able-bodied enough to work but whose quality of life has been severely affected by their illness.