The U.S. Court of Appeals for the Sixth Circuit denied Island Creek Kentucky Mining's petition for review in a black lung benefits case, upholding a decision that awarded compensation to coal miner Eddie Stewart under the Black Lung Benefits Act.
In the opinion filed Feb. 4, 2026, a three-judge panel consisting of Circuit Judges Clay, Kethledge, and Bush rejected the mining company's challenge to a Benefits Review Board ruling. Judge Clay authored the court's opinion denying the petition for review.
The case originated when Eddie Stewart filed a claim for benefits under the Black Lung Benefits Act against Island Creek Kentucky Mining. An administrative law judge initially awarded benefits to Stewart, finding him entitled to compensation under the federal program designed to assist coal miners suffering from pneumoconiosis, commonly known as black lung disease.
The Benefits Review Board subsequently affirmed the administrative law judge's decision to award benefits. Island Creek Kentucky Mining then petitioned the Sixth Circuit Court of Appeals for review of the board's affirmance, seeking to overturn the benefits award.
The Black Lung Benefits Act, codified at 30 U.S.C. § 901 et seq., was enacted by Congress to provide benefits for coal miners who become totally disabled due to pneumoconiosis. As the court noted in its opinion, the law aims to provide compensation "for or on behalf of [coal] miners who are totally disabled due to pneumoconiosis."
The federal benefits program addresses the occupational health risks faced by coal miners, who can develop serious lung diseases from prolonged exposure to coal dust in mines. Pneumoconiosis, or black lung disease, results from the inhalation of coal dust particles that accumulate in the lungs over time, causing inflammation, scarring, and breathing difficulties.
In denying Island Creek Kentucky Mining's petition, the Sixth Circuit upheld the existing administrative determinations that found Stewart entitled to benefits under the act. The court's decision means the Benefits Review Board's affirmance of the administrative law judge's award stands.
The opinion references Island Creek Coal Co. v. Maynard ex rel. Maynard, 87 F.4th 802, 807 (6th Cir.), indicating the court relied on established Sixth Circuit precedent in reaching its decision. This suggests the court found the case fell within well-established parameters for black lung benefits awards.
Black lung benefits cases typically involve detailed medical evidence regarding a miner's work history, exposure to coal dust, and the resulting health impacts. Administrative law judges must evaluate medical testimony, employment records, and expert opinions to determine whether a claimant qualifies for benefits under the statutory framework.
The Benefits Review Board serves as an intermediate appellate body that reviews administrative law judge decisions in black lung cases before they can be appealed to federal circuit courts. The board's role is to ensure consistency in the application of the Black Lung Benefits Act across different cases and administrative law judges.
Island Creek Kentucky Mining's unsuccessful petition demonstrates the challenges mining companies face when contesting benefits awards that have been affirmed through multiple levels of administrative review. Federal circuit courts generally defer to administrative expertise in evaluating the medical and factual evidence in black lung cases.
The court designated its opinion "NOT RECOMMENDED FOR PUBLICATION," indicating it does not establish new legal precedent but rather applies existing law to the specific facts of Stewart's case. Such unpublished opinions are common in cases involving straightforward applications of established legal principles.
For Eddie Stewart, the Sixth Circuit's denial of the petition means he will continue to receive the black lung benefits awarded by the administrative law judge. These benefits typically include monthly compensation payments and coverage for medical treatment related to the miner's pneumoconiosis.
The case reflects the ongoing litigation surrounding black lung benefits as coal miners seek compensation for occupational lung diseases while mining companies contest awards they believe are unwarranted. The Black Lung Benefits Act remains a crucial safety net for miners who develop serious respiratory conditions from their work in coal mines.
The Sixth Circuit's jurisdiction includes Kentucky, where Island Creek Kentucky Mining operates, making it the appropriate appellate court for reviewing Benefits Review Board decisions in cases involving Kentucky-based mining operations and workers.