Court Overturns Black Lung Award, Clarifies Burden of Proof for Legal Pneumoconiosis Claims

A divided federal appellate court overturned an award of black lung benefits to a coal miner based on an administrative law judge’s misapplication of the burden of proof for a legal pneumoconiosis claim. Bruce E. Goode worked for American Energy LLC as a coal miner off and on for more than 12 years. He filed a claim under the Black Lung Benefits Act for his severe chronic obstructive pulmonary disability in 2013. Because Goode was a longtime smoker, American Energy disputed the cause of his impairment. An administrative law judge found that Goode’s condition arose from...