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Home / Decisions / United States Court of Appeals for the Seventh Circuit / Jeffboat, Inc. and American Longshore Mutual Association, Ltd. v. Director, Office of Workers' Compensation Programs
7th Cir.

Jeffboat, Inc. and American Longshore Mutual Association, Ltd. v. Director, Office of Workers' Compensation Programs

Jeffboat, Inc. and American Longshore Mutual Association, Ltd. v. Director, Office of Workers’ Compensation Programs

June 23, 2026 ·24-2234 ·Panel Decision ·Maldonado · By Raj Patel

The Seventh Circuit affirmed a benefits determination awarding workers' compensation to a ship painter under the Longshore and Harbor Workers' Compensation Act. The court held that the administrative law judge's findings were supported by substantial evidence despite conflicting expert testimony.

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Key takeaways

  • Holding: The court affirmed the administrative law judge's award of partial disability benefits and attorneys' fees, finding the decision supported by substantial evidence.
  • Standard: Substantial evidence standard
  • Vote: Panel Decision
  • Practical effect: 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.

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.

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Background The court’s reasoning What it means going forward

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