Clinchfield Coal Company v. Director, Office of Workers' Compensation Programs
Clinchfield Coal Company v. Director, Office of Workers’ Compensation Programs
July 14, 2026·24-2170·Per Curiam·By Raj Patel
The United States Court of Appeals for the Fourth Circuit denied a petition for review regarding an award of black lung benefits. The court found the Benefits Review Board's decision supported by substantial evidence and free of reversible error.
Clinchfield Coal Company, represented by HealthSmart Casualty Claims Solutions, petitioned for review of an order from the Benefits Review Board. The Board had affirmed an Administrative Law Judge’s award of black lung benefits to Kellis C. Barton under the Federal Black Lung Benefits Act.
The court’s reasoning
The court stated that its review is limited to determining whether substantial evidence supports the factual findings of the Administrative Law Judge and whether the legal conclusions are rational. The court defined substantial evidence as more than a mere scintilla, meaning relevant evidence a reasonable mind might accept as adequate. Upon reviewing the record and arguments, the court concluded the Benefits Review Board’s decision was based on substantial evidence and contained no reversible error.
What it means going forward
The petition for review is denied, leaving the award of black lung benefits to Kellis C. Barton in place.
