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4th Circuit Denies Coal Company's Black Lung Benefits Challenge

The U.S. Court of Appeals for the Fourth Circuit denied Clinchfield Coal Company's petition challenging workers' compensation benefits awarded to former underground coal miner Vernon Vanderpool, who developed black lung disease after over two decades of mining work.

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4 min readcourtlistener
Seal of the Fourth Circuit Court of Appeals

Case Information

Case No.:
23-1667

Key Takeaways

  • Fourth Circuit unanimously denied Clinchfield Coal Company's petition challenging black lung benefits
  • Vernon Vanderpool worked over 20 years underground before developing pneumoconiosis
  • Administrative Law Judge and Benefits Review Board previously upheld the benefits award
  • Decision reinforces federal protections for coal miners with occupational respiratory diseases

The U.S. Court of Appeals for the Fourth Circuit denied Clinchfield Coal Company's petition for review of a black lung benefits award, upholding compensation for a former underground coal miner who developed pneumoconiosis after more than 20 years in the mines.

In a published opinion issued Jan. 15, 2026, a three-judge panel unanimously rejected the coal company's challenge to benefits awarded to Vernon Vanderpool under the Black Lung Benefits Act. Judge Roger Gregory wrote the opinion, joined by Judges J. Harvie Wilkinson III and Toby Heytens.

Vanderpool worked in underground coal mines for over two decades, serving as both a roof bolter and section foreman before retiring due to a back injury. Years after his retirement, Vanderpool began experiencing progressive shortness of breath, wheezing, and other respiratory symptoms that limited his physical exertion. He was eventually diagnosed with pneumoconiosis, commonly known as black lung disease.

On Aug. 15, 2014, Vanderpool filed a claim with the U.S. Department of Labor, reporting that his respiratory ailments had become totally disabling and seeking compensatory benefits under the Black Lung Benefits Act. The federal statute provides compensation to coal miners who develop pneumoconiosis as a result of their employment in coal mines.

In September 2016, a District Director of the DOL's Office of Workers' Compensation Programs issued a Proposed Decision and Order awarding benefits to Vanderpool. An Administrative Law Judge subsequently upheld that award, finding that Vanderpool met the requirements for compensation under the Act.

Clinchfield Coal Company, represented by Penn, Stuart & Eskridge, challenged the benefits determination through the administrative appeals process and ultimately petitioned the Fourth Circuit for review. The company argued against the ALJ's findings that supported Vanderpool's entitlement to benefits.

The case proceeded through the Benefits Review Board before reaching the Fourth Circuit. Oral arguments were held Oct. 21, 2025, with Kendra Prince representing Clinchfield Coal and Mary Rachel Wolfe representing Vanderpool and the Department of Labor.

The Fourth Circuit's decision represents the latest development in ongoing litigation over black lung benefits, which have become increasingly contentious as mining companies face growing claims from workers who developed respiratory diseases after years of coal dust exposure. The Black Lung Benefits Act, enacted in 1969 and amended several times since, establishes a federal compensation program for miners disabled by pneumoconiosis.

Pneumoconiosis develops when coal dust accumulates in miners' lungs over years of exposure, causing progressive scarring and breathing difficulties. The disease can continue to worsen even after miners leave the industry, often leading to severe disability and premature death.

The Fourth Circuit has jurisdiction over appeals from coal mining regions in Virginia, West Virginia, and other Appalachian states where black lung disease remains a significant occupational health concern. Federal data shows thousands of former coal miners continue to file claims for benefits under the Act each year.

Under the Black Lung Benefits Act, eligible miners or their survivors can receive monthly compensation payments, medical treatment coverage, and other benefits. To qualify, claimants must demonstrate they worked in coal mines and developed pneumoconiosis as a result of that employment.

The administrative process for black lung claims begins with the Department of Labor's Office of Workers' Compensation Programs, where district directors initially review applications. Contested cases proceed to administrative law judges, and unsuccessful parties can appeal to the Benefits Review Board. Federal circuit courts provide the final level of review for these determinations.

Clinchfield Coal Company operates mining facilities in Virginia and other southeastern states. The company was represented in the case through HealthSmart Casualty Claims Solutions, which handles workers' compensation matters.

The Fourth Circuit's denial of the petition means Vanderpool's benefits award stands as affirmed by the lower administrative tribunals. The court's published opinion will serve as precedent for future black lung cases in the circuit.

Mining industry representatives have expressed concerns about the financial impact of black lung claims on coal companies, particularly smaller operators. However, miners' advocates argue that workers who sacrificed their health in dangerous underground conditions deserve comprehensive compensation for occupational diseases.

The case reflects broader trends in black lung litigation, where coal companies increasingly challenge benefits determinations through federal courts. Medical advances have improved diagnosis of pneumoconiosis, while legal developments have expanded eligibility criteria in some circumstances.

Vanderpool's successful claim adds to the growing body of Fourth Circuit precedent supporting miners' rights to compensation for occupational respiratory diseases. The decision reinforces the federal commitment to providing benefits for workers who developed black lung disease during their coal mining careers.

Topics

black lung diseasepneumoconiosiscoal miningworkers' compensationadministrative lawappellate review

Original Source: courtlistener

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