Background
Calvin Chaffers, a ship painter for Jeffboat, Inc., filed a claim for workers’ compensation under the Longshore and Harbor Workers’ Compensation Act after developing breathing difficulties from exposure to toxic chemicals. Jeffboat disputed the claim, presenting expert testimony that Chaffers’ symptoms were likely caused by pre-existing conditions rather than workplace exposure. An administrative law judge awarded Chaffers partial disability benefits and attorneys’ fees, a decision affirmed by the Benefits Review Board.
The court’s reasoning
The Seventh Circuit reviewed the administrative law judge’s decision under the deferential substantial evidence standard. The court found that Chaffers met the initial burden to establish a prima facie case by showing harm and workplace conditions that could cause it. Although the employer rebutted the presumption of causation, the administrative law judge properly credited the claimant’s expert over the employer’s expert, noting the employer’s expert failed to explain why the known harmful exposures did not cause the injury. The court emphasized that it cannot reweigh evidence or substitute its judgment for that of the administrative law judge.
What it means going forward
The ruling reinforces the deferential standard of review applied to administrative law judges in workers’ compensation cases, confirming that courts will not substitute their own factual findings for those of the agency when supported by substantial evidence.