The U.S. Court of Appeals for the Fourth Circuit denied Dominion Coal Corporation's petition for review of a black lung benefits award, upholding federal compensation for coal miner Darrell G. Meade in a case that involved constitutional challenges to administrative law judges' authority.
In a published opinion issued Jan. 15, Chief Judge Albert Diaz wrote for a unanimous three-judge panel that included Circuit Judges Andre Wynn and Toby Harris. The court rejected Dominion Coal's arguments challenging both the Benefits Review Board's standard of review and the constitutional authority of the administrative law judge who decided the case.
The case centers on Meade's application for benefits under the Black Lung Benefits Act, federal legislation that provides compensation to coal miners who develop pneumoconiosis, commonly known as black lung disease, from prolonged exposure to coal dust. The disease causes scarring of lung tissue and can lead to severe breathing difficulties and death.
Meade's path to benefits involved multiple administrative proceedings. An administrative law judge initially denied his claim for black lung benefits. However, the Benefits Review Board vacated that decision in part, holding that the judge had not adequately evaluated the evidence or provided sufficient explanation for the denial.
On remand, the administrative law judge reconsidered the case and granted Meade benefits. The Benefits Review Board then affirmed this decision, setting the stage for Dominion Coal's appeal to the federal courts.
Dominion Coal Corporation, which employed Meade, challenged the award on two primary grounds. First, the company argued that the Benefits Review Board failed to apply the appropriate standard of review when examining the administrative law judge's decision to grant benefits. This procedural argument goes to the heart of how federal agencies review administrative decisions and the level of deference courts should give to administrative findings.
Second, Dominion Coal raised a constitutional challenge, contending that the administrative law judge lacked authority to decide the case because federal protections against removal of administrative law judges violate the Constitution. This argument reflects broader legal debates about the independence of administrative adjudicators and separation of powers principles.
The constitutional challenge relates to ongoing disputes about the structure of federal administrative agencies and the extent to which administrative law judges can be insulated from executive oversight. Some employers and legal scholars have argued that tenure protections for administrative law judges create constitutional problems by limiting the President's ability to control executive branch officials.
The Fourth Circuit's denial of the petition means that Meade will continue to receive benefits under the Black Lung Benefits Act. The court's published opinion provides precedent for similar cases involving challenges to administrative law judge decisions in workers' compensation matters.
The case was argued Dec. 9, 2025, before the three-judge panel. Charity Ann Barger of Street Law Firm represented Dominion Coal, while Brad Anthony Austin of Wolfe Williams & Austin represented Meade. The federal government was represented by David Casserly of the U.S. Department of Labor.
The black lung benefits program has been a source of ongoing litigation as coal companies frequently challenge awards to miners. The program, established in 1969, provides monthly payments and medical coverage to miners disabled by pneumoconiosis and to survivors of miners who died from the disease.
Statistics show that black lung disease continues to affect coal miners despite safety improvements in mining operations. The disease typically develops after years of exposure to coal dust, and symptoms may not appear until after miners have left the industry.
Dominion Coal's unsuccessful challenge reflects the difficulty companies face when appealing administrative decisions that follow proper procedures. Federal courts generally defer to administrative expertise in workers' compensation matters, particularly when agencies follow established review processes.
The Fourth Circuit's jurisdiction includes several coal-producing states, making it a frequent venue for black lung benefits disputes. The court's published opinion will guide future cases involving similar procedural and constitutional challenges to administrative law judge decisions.
For Meade and his family, the Fourth Circuit's decision provides finality after years of administrative and judicial proceedings. Black lung benefits typically include monthly disability payments and coverage for medical expenses related to treating pneumoconiosis.
The case demonstrates the complex procedural path that black lung benefits claims often follow, from initial administrative decisions through multiple levels of review. While Dominion Coal could potentially seek Supreme Court review, the unanimous Fourth Circuit decision and the case's fact-specific nature make further appeal uncertain.