American Textile Mfrs. Institute, Inc. v. Donovan (1980)
- Docket
- 79-1429
- Decided
- 1980-01-01
Summary
Question: Does the Occupational Safety and Health Act require OSHA to demonstrate that the reduction of risk is significant enough to offset the costs of adopting a new standard? Conclusion: No. Justice William J. Brennan, Jr. delivered the opinion of the 5-3 majority. The Court held that that the language of the Act requires OSHA to engage in feasibility analysis but not a cost-benefit analysis. The legislative history of the Act indicates that Congress understood that new standards would create significant costs for employers but found the costs necessary to create safe working environments. The Court also held that OSHA reasonably evaluated the cost and feasibility of implementing the standards, and that the decision to implement was supported by substantial evidence. Justice Potter Stewart wrote a dissenting opinion where he argued that OSHA did not have substantial evidence to justify its determination of the cost and therefore did not effectively show that the standard was economically feasible. In his separate dissent, Justice William H. Rehnquist wrote that the Act unconstitutionally delegated policy-making authority from the legislative branch of government to an unelected official in the executive branch. He argued that the legislative history of the Act shows that Congress could not decide exactly how much authority OSHA should have in enacting standards, so the feasibility requirement represented a Congressional compromise rather than a decision. Chief Justice Warren E. Burger joined in the dissent. Justice Lewis F. Powell, Jr. did not participate in the discussion or decision of this case.