Patricia Watson v. Secretary of Labor
2012 U.S. App. LEXIS 16674
| 6th Cir. | 2012Background
- Patricia Watson challenged DOL’s interpretation of the Energy Employees Occupational Illness Compensation Program Act (2000) regarding survivor benefits for a “covered child.”
- Watson’s father, Ethrage J. Hickle, worked for DOE 1954–1962 and died in 1964 from Hodgkin’s disease.
- Watson, age 19 at death and not a full-time student, lived with parents and depended on them for support.
- Watson filed a survivor claim in 2002 seeking benefits under 42 U.S.C. § 7385s-3(d)(2)(C) for being “incapable of self-support.”
- DOL denied the claim, relying on its policy requiring physical or mental incapacity evidence; district court denied summary judgment; Watson appealed challenging the Department’s interpretation.
- Court affirmed district court, upholding DOL’s interpretation and denial of benefits as not arbitrary or capricious.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is ‘incapable of self-support’ ambiguous and subject to agency interpretation? | Watson argues the term is unambiguous and not limited to physical/mental incapacity. | Department contends the term is ambiguous and its physical/mental incapacity interpretation is permissible. | Ambiguous; department interpretation persuasive under Skidmore. |
| Was the DOL’s interpretation entitled to deference and its application non-arbitrary? | Watson contends the interpretation is inconsistent with the statute’s text. | DOL’s approach aligns with other statutes and is thoroughly reasoned. | Department’s interpretation persuasive and not arbitrary or capricious. |
| Did Watson prove she was physically or mentally incapable of self-support to qualify as a “covered child”? | Watson contends she met incapability criteria. | Watson failed to submit medical/physical evidence of incapacity. | DOL did not act arbitrarily; lack of evidence supported denial. |
Key Cases Cited
- Chao v. Occupational Safety & Health Review Comm'n, 540 F.3d 519 ((6th Cir. 2008)) (establishes Chevron two-step framework and Skidmore deference)
- Chevron U.S.A., Inc. v. NRDC, 467 U.S. 837 () (establishes step-one/step-two framework for agency interpretation)
- Skidmore v. Swift & Co., 323 U.S. 134 () (deference based on persuasiveness of agency interpretation)
- Hayward v. U.S. Dep’t of Labor, 536 F.3d 376 (5th Cir. 2008) (relevant discussion of benefits and interpretation)
- Harger v. Dep’t of Labor, 560 F.3d 1071 (9th Cir. 2009) (supported interpretation of incapacity)
- OfficeMax, Inc. v. United States, 428 F.3d 583 ((6th Cir. 2005)) (rejected implausible interpretive read of long-standing practice)
- Cox v. Standard Ins. Co., 585 F.3d 295 ((6th Cir. 2009)) (arbitrary-and-capricious review requires a reasoned explanation)