11th Circuit Clarifies Application of BLBA's 'Automatic Entitlement' Provision

The U.S. 11th Circuit Court of Appeals ruled that the Black Lung Benefits Act provides for an automatic award to the survivors of miners who were eligible before death. Case: Oak Grove Resources v. Director OWCP, Nos. 7-14468 and 17-15782, 04/11/2019, published. Facts and procedural history: Lee Ferguson and Luther Terry both worked as coal miners. Ferguson filed a claim under the BLBA in July 2012. His claim was denied, and he appealed. Ferguson died in November 2014 while his appeal was pending. His widow filed a claim for survivors' benefits in March 2015. In November 2015...