Case Explained: CLINCHFIELD COAL COMPANY, c/o HealthSmart Casualty Claims Solutions v. DIRECTOR, OFFICE OF WORKERS’ COMPENSATION PROGRAMS, UNITED STATES DEPARTMENT OF LABOR; KELLIS C. BARTON

Court: United States Court of Appeals for the Fourth Circuit

Filed: 2026-07-14

The fourth-circuit denied Clinchfield Coal Company’s petition for review of the Benefits Review Board’s order affirming an Administrative Law Judge’s award of black lung benefits under 30 U.S.C. §§ 901-944. The court applied the standard that its review is limited to determining whether substantial evidence supports the ALJ’s factual findings and whether the legal conclusions of the ALJ and Board are rational and consistent with applicable law, defining substantial evidence as more than a mere scintilla—specifically, relevant evidence a reasonable mind might accept as adequate to support a conclusion. Finding that the Board’s decision was supported by substantial evidence and free of reversible error, the court denied the petition without oral argument, leaving the award of benefits in effect.

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