A federal appeals court upheld a lower court ruling allowing a coal miner’s widow to collect under the Black Lung Benefits Act despite two medical opinions that blamed his lung disease on smoking.
The U.S. 6th Circuit Court of Appeals found that an administrative law judge properly relied on a third doctor’s opinion that the miner’s chronic obstructive pulmonary disease (COPD) was at least partially caused by coal dust.
10 years as miner, 30 years as 2-pack-per-day smoker
James Clemons died from COPD in 2015, after having filed a claim for benefits under the Black Lung Benefits Act the year before. A previous claim filed in 2010 had been denied for lack of sufficient medical evidence proving Clemons had pneumoconiosis.
After Clemons’ death, his widow picked up the claim to pursue survivor benefits.
Clemons had been a coal miner with Huscoal Inc. for 10 years before his death. He also had a long history of cigarette smoking which saw him smoke two packs per day for 30 years.
Clinical or legal pneumoconiosis?
In court, it was an undisputed fact that after developing COPD, Clemons became totally disabled and eventually died from the disease. The only point of contention was whether or not substantial evidence proved his disabling condition could be considered legal pneumoconiosis.
Clinical pneumoconiosis covers certain, specific lung diseases the medical community recognizes to be caused by exposure to coal dust. Legal pneumoconiosis is much broader, covering any chronic lung disease or impairment arising from coal mine employment.
In order to qualify for benefits under the Black Lung Benefits Act, a claimant has to prove that the:
- miner has either clinical or legal pneumoconiosis
- pneumoconiosis arose at least in part out of the miner’s coal-mine employment
- miner is totally disabled, and
- total disability is due to pneumoconiosis.
Clemons’ widow was awarded benefits in January 2018. Huscoal appealed, and the claim was referred to the Office of Administrative Law Judges.
An administrative law judge conducted a hearing in October 2019 and issued a decision awarding benefits to the widow in May 2020.
Conflicting medical opinions based on inaccurate info
The judge found evidence didn’t support a finding of clinical pneumoconiosis, but it did support a finding of legal pneumoconiosis.
In coming to this conclusion, the judge had considered medical opinions from three doctors, two who claimed Clemons’ COPD was from smoking and one who said the condition was both from smoking and from coal-mine dust exposure. To further confuse matters, each of the three doctors relied on somewhat inaccurate information about Clemons’ smoking habits and years working as a coal miner.
The judge found the doctor who claimed the COPD was from coal dust and smoking provided a more convincing reason – which adequately linked both to Clemons’ condition – for his diagnosis than the other two, who failed to provide sufficient details in their notes. The other two doctors also relied on chest X-rays, which are only valid for establishing clinical pneumoconiosis.
This led the judge to grant benefits to Clemons’ widow. The Benefits Review Board affirmed the decision and Huscoal appealed.
Reliance on doctor’s detailed diagnosis was warranted
In denying Huscoal’s petition to appeal, the 6th Circuit found that substantial evidence supported the judge’s conclusion.
The court also found the judge had good reason for relying on the one doctor’s medical opinion over the other two considering the amount of documentation and detail offered in his diagnosis.