Facts support denying miner’s black lung claim despite messy record
The U.S. Department of Labor might have mishandled a coal worker’s pneumoconiosis claim, but its denial was nonetheless backed by substantial evidence, the 6th U.S. Circuit Court of Appeals ruled Thursday.
Casey Samons developed the condition commonly known as black lung disease after working in underground coal mines for 30 years. His widow engaged in a 17-year fight to receive benefits that ended in 2020 with the Benefits Review Board denying the claim.
The appeals court noted that the Labor Department further delayed the case by filing an incomplete and disorganized administrative record, according to documents in Mabel Samons v. National Mines Corp., filed in Cincinnati, Ohio.
“We thus understand Samons’ frustrations with the agency’s handling of her claims,” the court said. “But while its actions perhaps could be described as poor customer service, they do not show any reversible legal error in the agency proceedings.”
The federal Black Lung Benefits Act allows coal miners and survivors to seek benefits for pneumoconiosis if they contracted the disease through employment and it contributes to their total disability.
Mr. Samons worked in Kentucky coal mines from 1946 to 1976. He filed a claim for benefits in 2003 but died two years later while the claim was pending. His widow took up the claim on behalf of his estate and filed her own claim for survivor’s benefits.
After a federal administrator initially awarded benefits on both claims, the case was appealed several times, ruling in favor of the employer. The appeals court affirmed, saying it was not persuaded by the argument that the findings were not supported by substantial evidence.
The court, however, agreed that the administrative record was in shambles, yet it rejected the argument that the Black Lung Disability Trust Fund should pay benefits.
WorkCompCentral is a sister publication of Business Insurance. More stories here.
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