JEFFREY HAYES v. DIRECTOR, OWCP UNITED STATES DEPARTMENT OF LABOR COWIN & COMPANY, INC
The Eleventh Circuit vacated a Benefits Review Board decision, clarifying that the Black Lung Benefits Act does not require a miner to prove employment for a full 365-day calendar year to count as a year of service. Instead, the court held that working 125 days in coal mines during a calendar year is sufficient to establish a year of employment for benefit eligibility.