Background
Russell T. Fridley received an award of miner’s benefits under the Black Lung Benefits Act from an administrative law judge, and the Benefits Review Board affirmed. Hobet Mining and Arch Resources petitioned for review, not to dispute Fridley’s entitlement to benefits, but to challenge the finding that Arch was liable for payment of those benefits.
The court’s reasoning
The court said its recent decision in Hobet Mining, Incorporated versus Director, Office of Workers’ Compensation Programs, referred to as Meredith, controlled because the relevant factual circumstances were identical. Relying on Meredith, the court concluded that the administrative law judge erred in assigning liability to Arch for payment of Fridley’s benefits. The court therefore vacated the Benefits Review Board’s order and remanded for entry of an order directing the Black Lung Disability Trust Fund to pay the benefits.
nothing in the regulations concerning black lung insurance justifie[d] imposing liability on Arch for [the miner’s] benefits.
Hobet Mining, Inc. v. Director, Office of Workers’ Compensation Programs, 156 F.4th 385, 399 (4th Cir. 2025)
What it means going forward
Fridley’s benefits remain payable, but the payment obligation shifts away from Arch Resources and to the Black Lung Disability Trust Fund on remand.