Federal Court Clarifies Duration of 'Year' of Employment for Black Lung Benefits

A federal appellate court ruled that a “year” of employment under the Black Lung Benefits Act occurs when a coal miner works 125 days or more in and around a coal mine during a one-year period. Case: Baldwin v. OWCP, No. 23-1947, 03/19/2026, published. Facts: Eddie Baldwin worked in Virginia coal mines for Island Creek Kentucky Mining from 1976 until 1991. Procedural history: In July 2018, Baldwin filed a claim under the Black Lung Benefits Act. A district director overseeing Baldwin’s claim issued a proposed decision and order in 2020, finding that Baldwin had been emplo...