The West Virginia Supreme Court of Appeals has affirmed a decision that awarded zero disability benefits to a coal miner diagnosed with occupational pneumoconiosis, commonly known as black lung disease. In a memorandum decision filed Jan. 13, 2026, the court upheld lower court rulings in *Terry Kyle v. Patriot Coal Corporation*.
Terry Kyle, who worked as a coal miner until November 2015, filed for workers' compensation benefits after being diagnosed with mild occupational pneumoconiosis. Kyle ceased working due to health issues and reported experiencing shortness of breath when walking, bending over, and carrying groceries. Despite his diagnosis and symptoms, the claim administrator awarded him a 0% permanent partial disability rating in May 2023.
The case originated when Kyle completed an employees' and physicians' report of occupational pneumoconiosis in February 2022. Kyle indicated he was last exposed to occupational dust in November 2015 when he stopped working. The physicians' portion of the form was completed by Erica Stanley, APRN, FNP-BC, and Richard Spencer, M.D., who both indicated Kyle had mild occupational pneumoconiosis.
Following the medical evaluation and claim review process, Kyle appealed the 0% disability rating through the West Virginia workers' compensation system. The case proceeded through multiple levels of review, including the Workers' Compensation Board of Review and the Intermediate Court of Appeals, before reaching the state's highest court.
The Supreme Court's memorandum decision represents the final determination in Kyle's case, affirming that despite his black lung diagnosis and reported symptoms, he was not entitled to disability benefits under the state's workers' compensation framework. The decision highlights ongoing challenges faced by coal miners seeking compensation for occupational lung diseases in West Virginia.
