Armando Venicassa v. Consolidation Coal Company and Director, Office of Workers' Compensation Programs, United States Department of Labor

COWEN, Circuit Judge,

dissenting.

Today the majority holds that a district director is not authorized, under any circum*205stances, to correct a mistaken responsible operator identification. Because this holding is contrary to, inter alia, the Director’s reasonable interpretation of 20 C.F.R. § 725.412(a) and (c), congressional intent, and the Sixth Circuit’s decisions in Caudill Construction Co. v. Abner, 878 F.2d 179 (6th Cir.1989) and Director, OWCP v. Oglebay Norton Co., 877 F.2d 1300 (6th Cir.1989), I must respectfully dissent.

I.

The standards governing our review of an agency’s interpretation1 of its own regulations are well known and not in dispute. We owe “substantial deference” to the agency’s interpretation, which has “ ‘controlling weight unless it is plainly erroneous or inconsistent with the regulation.’ ” Thomas Jefferson Univ. v. Shalala, 512 U.S. 504, 512, 114 S.Ct. 2381, 2386, 129 L.Ed.2d 405 (1994) (quoting Bowles v. Seminole Rock & Sand Co., 325 U.S. 410, 414, 65 S.Ct. 1215, 1217, 89 L.Ed.1700 (1945)); see also Sekula v. FDIC, 39 F.3d 448, 453 (3d Cir.1994). Absent constitutional or statutory violations, the only circumstance in which we do not defer is where “an ‘alternative reading is compelled by the regulations’s plain language or by other indications of the [agency’s] intent at the time of the regulation’s promulgation.’ ” Thomas Jefferson JJniv., 512 U.S. at 512,114 S.Ct. at 2386-87 (quoting Gardebring v. Jenkins, 485 U.S. 415, 430, 108 S.Ct. 1306, 1314, 99 L.Ed.2d 515 (1988)). “In addition, we give judicial deference to the Director, as policymaker, rather than to the Board, which is purely an adjudicator.” Director, OWCP v. Eastern Coal Corp., 54 F.3d 141, 147 (3d Cir.1995) (citations omitted). I believe that the majority fails to adhere to these fundamental principles. Indeed, the most striking aspect of the majority’s opinion is its complete failure even to mention our duty, under most circumstances, to defer to an agency’s interpretation of its own regulations.

II.

Section 725.412 provides, in pertinent part, as follows:

(a) At any time during the processing of a claim under this part, after sufficient evidence has been made available to the [district director], the [district director] may identify a coal miner [sic] operator (see § 725.491) which may be liable for payment of the claim____ Such identification shall be made as soon after the filing of the claim as the evidence obtained permits ____
(c) If within one year after the final adjudication of a claim, the adjudication officer determines that an operator which may be liable for the payment of benefits has not been notified under this section, such adjudication officer shall give notice of possible liability and an opportunity to respond to such operator. The adjudication officer shall then take such further action on the claim as may be appropriate.

20 C.F.R. § 725.412(a), (c).

A The Director’s Interpretation

According to the Director, section 725.412 provides that: (1) a district director1 is authorized to correct mistaken responsible operator identifications; (2) such corrections may occur “at any time” during the processing of a claim, and up to one year after final adjudication; and (3) a district director has no duty—beyond the “at any time” limitation above—to identify a responsible operator within a reasonable time after the information necessary to make an identification becomes available to him. Each of these contentions will be addressed in turn.

1. Ability to Make Corrections

The Director asserts that section 725.412' “clearly authorizes the correction of a mistaken responsible operator identifica-tion____” Respondent’s Br. at 12. I agree. There is simply nothing in the regulation that is inconsistent with this interpretation. *206Nor does this interpretation conflict with any statutory or constitutional provisions. On the contrary, the Director’s view effectuates clear congressional intent to limit Trust Fund liability to those instances in which no responsible operator can be identified. See 26 U.S.C. § 9501(d). Moreover, it is supported by two persuasive Sixth Circuit decisions. See Oglebay, 877 F.2d at 1305 (corrections permitted pursuant to section 725.412(a)); Caudill Const., 878 F.2d at 181 (corrections permitted pursuant to section 725.412(c)). Consequently, we must defer to the Director’s reasonable interpretation.

2. Timing of Corrections

The Director next contends that section 725.412(a) and (c) authorize the district director or ALJ to correct a mistaken responsible operator identification “at any' time” during the processing of a claim, and up to one year after a final adjudication. The Director also contends that the ability to make such corrections is not limited to cases—such as this one—where an attempt to correct a mistaken identification occurs prior to final adjudication of a claim.

Once again, the Director’s interpretation is not inconsistent with the regulation. Moreover, it is not inconsistent with due process. Due process is simply not implicated when— as here—an attempt to correct a misidentifi-cation is made prior to final adjudication of the claim.2 Cf. Caudill Const, 878 F.2d at 181 (district director authorized to correct misidentification of responsible carrier “even where a final compensation order;, has been issued against the operator”). While it might seem unfair to require a claimant who has already proven entitlement once to have to prove it again, relitigation of a finally-decided claim is not unprecedented in the black lung program. The, statutorily prescribed modification procedure, for example, allows a fact finder, upon any party’s motion, to review previously-considered facts . and find a “mistake in a determination of fact.” 20 C.F.R. § 725.310. Indeed, the Supreme Court has observed that

the plain import of [the modification statute] was to vest a [district director] with broad discretion to correct mistakes of fact, whether demonstrated by wholly new evidence, cumulative evidence, or merely further reflection on the evidence initially submitted.

O’Keeffe v. Aerojet-General Shipyards, Inc., 404 U.S. 254, 256, 92 S.Ct. 405, 407, 30 L.Ed.2d 424 (1971) (per curiam). Thus, “the statute and regulations give the [district director] the authority, for one year after the final order on the claim, to simply rethink a prior finding of fact.” Jessee v. Director, OWCP, 5 F.3d .723, 724-25 (4th Cir.1993).

In addition, Venicassa had no expectation of finality in the ALJ’s 1989 award of benefits. See id. (“[T]he “principle of finality” just does not apply to Longshore Act and black lung claims as it does in ordinary lawsuits.”). The Director appealed that decision to the Board, arguing not only that the ALJ had erroneously denied the remand motion, but, that he had erred in awarding benefits.3 Venicassa had no reason, therefore, to believe that the ALJ’s award settled the issue of his entitlement to benefits. His entitlement remained at issue regardless of the identity of the hable party. We must defer to the Director’s interpretation of this regulation.

S. Duty to Identify as Soon as Evidence Permits

Finally, the Director asserts that it is inappropriate to mandate identification of a re*207sponsible operator within a reasonable time after the information necessary to make an identification becomes available to the district director. Such a reading, according to the Director, “essentially reads a time limitation into the regulation that “would inject a degree of uncertainty into future responsible operator identifications.’ ” Respondent’s Br. at 30 (quoting Oglebay, 877 F.2d at 1303).

The Director’s interpretation of this language is inconsistent with the regulation. While section 725.412(a) includes the phrase “at any time during the processing of the claim,” it also includes the phrase “[s]uch identification shall be made as soon after the filing of the claim as the evidence obtained permits.” Thus, the Director impermissibly reads the second phrase completely out of the regulation for all practical purposes. See Oglebay, 877 F.2d at 1306-07 (Wellford, J., dissenting). Because meaning must be given to every word “so that no part will be inoperative or superfluous, void or insignificant,” Sekula, 39 F.3d at 454-55 n. 16, this aspect of the Director’s interpretation is entitled to no deference.

U. Conclusion

Based on the foregoing, I conclude that a district director is authorized to correct a mistaken responsible operator identification at any time prior to final adjudication of a claim. However, such corrections must be made within a reasonable time after the information necessary to make such a correction becomes available to him. Because the Director sought to correct the mistaken identification in this case approximately eighteen months before final adjudication of the claim, he acted within a reasonable time, and the ALJ should have granted his motion to remand. I would therefore affirm the Board’s decision to vacate Venicassa’s award so that the ALJ could designate the proper responsible operator.

B. The Majority’s Interpretation

According to the majority, section 725.412(a) must be interpreted as follows:

While the regulation clearly states that the designation of the responsible operator may be made “at any time,” the language of the regulation triggers the process by providing that the designation be made “after sufficient evidence has been made available to the deputy commissioner.” The regulation then further limits the process by providing that the designation “shall be made as soon after the filing of the claim as evidence obtained permits.” 20 C.F.R. § 725.412(a). The focus of the regulation is clearly on the swift and accurate designation of the responsible operator so that the claim may be resolved through the presentation of evidence to the fact finder by the appropriate parties.

Maj. Op. at 203.

While the majority properly concludes that section 725.412(a) requires the designation of a responsible operator as soon as the evidence reasonably permits, see Oglebay, 877 F.2d at 1306-07 (Wellford, J., dissenting), it fails to provide any mechanism for the correction of a mistaken responsible operator identification, regardless of how quickly and reasonably the attempted correction is made. See Maj. Op. at 202 (“The ALJ’s decision [to deny the Director’s motion to remand] places the incentives in the proper place—the Director should have gotten it right the first time. That would not have been an onerous task, because, from the outset, the OWCP had in its possession all the information necessary to name the proper responsible operator.”) (emphasis added). This view is incorrect for several reasons.

First, the majority’s interpretation is inconsistent with, and completely ignores, our obligation to defer to an agency’s interpretation of its own regulations unless it is plainly erroneous or inconsistent with the regulation.4 Here, the Director reads section *208725.412 to permit the correction of mistaken responsible operator identifications. Because this.view is not “plainly erroneous or inconsistent with the regulation,” see Caudill Const Co., 878 F.2d at 181; Oglebay, 877 F.2d at 1305, it is entitled to substantial deference.

Second, the majority’s conclusion that a district director is never authorized to correct a mistaken responsible operator identification fails to give any effect whatsoever to section 725.412(c). Such a reading violates our duty “to give each word of the [regulation] operative effeet[,]” Smith v. Magras, 124. F.3d 457, 462 (3d Cir.1997), and renders this provision “inoperative or superfluous, void or insignificant.” Sekula, 39 F.3d at 454-55 n. 16 (quotation marks omitted).

Third, the majority view is at odds with clear congressional intent, expressed over a period of years, to limit Trust Fund liability to instances in which no responsible operator can be identified. See 26 U.S.C. § 9501(d). In creating the Trust Fund, Congress intended to “ensure that individual coal operators rather than the trust fund bear the liability for claims arising Out of such operator’s mines to the maximum extent feasible.” S.Rep. No. 95-209, 95th Cong., 1st Sess. 9 (1977), reprinted in House Comm, on Educ. and Labor, 96th Cong., Black Lung Benefits Reform Act and Black Lung Benefits Revenue Act of 1977, 612 (Comm. Print 1979); see also Old Ben Coal, 826 F.2d at 693.

Finally, the majority’s interpretation also conflicts with the Sixth Circuit’s decision in Oglebay, where at least two judges (and possibly a third5) concluded that section 725.412(a) authorizes the correction of a mistaken responsible operator identification.6 It is also at odds with Caudill Construction, where the Sixth Circuit observed that subsection (c) “permits notification of a new operator where investigation reveals that pri- or identification was mistaken....” 878 F.2d at 181. Contrary to the majority’s interpretation of the regulation, it is clear that section 725.412(a) and (c) both authorize the correction of mistaken responsible operator identifications.

I respectfully dissent.

. A district director is a person authorized to develop and adjudicate claims for black lung benefits. For administrative purposes only, regulations substitute the term district director for the term deputy commissioner, which is found in the Longshore Act. See 20 C.F.R. § 725.101(a)(ll).

. Because a motion to remand was made prior to . final adjudication of the merits in this case, we need not consider the Director’s position that due process would not bar a district director’s attempt to correct a mistaken responsible operator identification when that attempt is not made until after final adjudication.

. By filing a motion to remand, and then renewing it at the hearing, the Director did everything within his control to correct the mistaken responsible operator identification before the ALJ awarded benefits payable by the Trust Fund. The Director could not order the ALJ to grant the motion, see Director, OWCP v. Newport News Shipbuilding and Dry Dock Co., 514 U.S. 122, 134, 115 S.Ct. 1278, 1287, 131 L.Ed.2d 160 (1995); Old Ben Coal Co. v. Luker, 826 F.2d 688, 696 n. 4 (7th Cir.1987), and an appeal to the Board at that point would have been interlocutory.

. The majority expressly disavows reaching its conclusion on due process grounds. See Maj. Op. at 203 n. 6. It does not, however, offer any reason why the Director's interpretation is not owed "substantial deference.” Indeed, rather than defer to the Director’s interpretation of its own agency guidelines, the majority defers to the Benefit Review Board’s interpretation of section 725.412 in Crabtree v. Bethlehem Steel Corp., 7 BLR 1-354 (1984). See id. at 202 ("In other words, the Crabtree concerns about due process and piecemeal litigation ... are greater in the instant case than were those faced by the court in Oglebay."). Such deference, however, is im*208proper for two reasons. First, "we give judicial deference to the Director, as policymaker, rather than to the Board, which is purely an adjudicator.” Eastern Assoc. Coal Corp., 54 F.3d at 147 (citations omitted). Second, Crabtree was wrongly decided because it fails to provide for the correction of mistaken responsible operator identifications and improperly injects a requirement into the regulation that the responsible operator must be identified at a preliminary proceeding. Crabtree; 7 BLR at 1-357; see also Director, OWCP v. Trace Fork Coal Co., 67 F.3d 503, 508 (4th Cir.l995)(requiring identification of a responsible operator at a preliminary proceeding).

. Although Judge Wellford expressed concern in his Oglebay dissent with "giving thei [district director] unfettered discretion to name a respon- • sible operator at any time, virtually without limitation]” 877 F.2d at 1306 (Wellford, J., dissenting), and with "encouragfing] sloppy and unreasonable administration of the Act[,]”'id. at 1307 (Wellford, J., dissenting), he did not consider whether section 725.412 authorized the correction of mistaken responsible operator identifications. It is interesting to note, however, that Judge Wellford joined the majority opinion in Caudill Construction, a case decided just seven days before Oglebay, which observed that section 725.412(c) "permits notification of a new operator where investigation reveals that prior identification was mistaken____” 878 F.2d at 181.

. The majority correctly observes that Oglebay is somewhat distinguishable from the instant cáse because correction of the mistaken responsible operator identification was made prior to final adjudication of the claim. However, this distinction is immaterial because, as noted above, relitigation of a finally-decided claim is: (1) consistent with the regulation; (2) consistent with congressional intent; (3) not uncommon in the black lung program; and (4) does not violate due process.