The West Virginia Supreme Court of Appeals filed a memorandum decision January 13, 2026, in a workers' compensation case involving the denial of death benefits to the widow of a deceased coal miner. Tammie Adams, dependent of Kenneth Adams (deceased), petitioned the high court to review a June 27, 2025, decision by the Intermediate Court of Appeals that upheld the denial of her claim for death benefits related to occupational pneumoconiosis.
The case centers on whether occupational pneumoconiosis, a lung disease commonly affecting coal miners, materially contributed to Kenneth Adams' death. The claimant argues that the Occupational Pneumoconiosis Board improperly disregarded medical evidence from her husband's treating physicians when concluding the disease did not contribute to his death.
The legal dispute began with a June 14, 2022, order from a claim administrator denying Adams' claim for death benefits. The West Virginia Workers' Compensation Board of Review affirmed this denial on November 25, 2024. The Intermediate Court of Appeals subsequently affirmed the Board of Review's decision on June 27, 2025, prompting Adams to seek review from the state's highest court.
Occupational pneumoconiosis is a progressive lung disease caused by prolonged inhalation of coal dust, affecting thousands of miners throughout Appalachia. Workers' compensation systems in coal-producing states like West Virginia have specific provisions for pneumoconiosis-related claims, recognizing the disease as an occupational hazard inherent to mining work.
The case involves multiple respondents, including Greyhead Mining Co., Inc., and Mohon Enterprises, Inc., both listed as employers in the proceedings. The Offices of the Insurance Commissioner, serving as administrator of West Virginia's Old Fund, also appears as a respondent. The Old Fund provides coverage for workers' compensation claims when employers cannot meet their obligations or for legacy claims from defunct mining operations.
Notably, court records indicate this represents a complex procedural history. The Occupational Pneumoconiosis Board had never formally determined that the decedent actually suffered from occupational pneumoconiosis. In a prior claim, Kenneth Adams had sought a permanent partial disability award for the condition, which was denied. The OP Board attributed the decedent's respiratory symptoms to other causes during those proceedings.
This procedural complexity highlights a common challenge in pneumoconiosis cases, where establishing both the existence of the disease and its causal relationship to death can prove difficult. Medical evidence often involves competing expert opinions about the extent to which coal dust exposure contributed to a miner's respiratory decline versus other factors such as smoking or other lung conditions.
Tammie Adams is represented by attorneys Reginald D. Henry and Lori J. Withrow, while the Insurance Commissioner's office is represented by Sean Harter. Significantly, neither Greyhead Mining Co., Inc. nor Mohon Enterprises, Inc. filed responses to the Supreme Court petition, potentially indicating their limited involvement in the current proceedings or agreement with the lower court decisions.
The Supreme Court's review comes at a time when occupational lung disease continues to affect West Virginia's mining workforce. Recent studies have documented rising rates of severe pneumoconiosis among younger miners, despite federal safety regulations designed to limit coal dust exposure. These trends have increased scrutiny of both workplace safety measures and the adequacy of workers' compensation coverage for mining-related diseases.
Workers' compensation systems typically require claimants to demonstrate that an occupational disease was a substantial contributing factor to a worker's death to qualify for death benefits. This standard can create significant evidentiary burdens for surviving family members, particularly when medical records show multiple potential causes of death.
The case number 25-573 reflects the Supreme Court's 2025 docket, with the underlying Intermediate Court of Appeals case numbered 24-ICA-510. The procedural history spans multiple years, illustrating the lengthy appeals process often required in complex workers' compensation disputes.
The Supreme Court's decision will have implications beyond this individual case, potentially clarifying standards for evaluating medical evidence in pneumoconiosis death claims. Given West Virginia's substantial mining industry and aging workforce of former miners, the court's guidance on these evidentiary standards could affect numerous pending and future claims.
The memorandum decision format suggests the court may resolve the case without full briefing and oral argument, though this preliminary filing does not indicate the ultimate scope of review the court will undertake. The justices will need to determine whether the Intermediate Court of Appeals properly applied existing precedent regarding the evaluation of medical evidence in occupational disease cases.
The outcome will determine whether Tammie Adams receives death benefits for her husband's occupational pneumoconiosis, while also establishing precedent for how West Virginia courts should evaluate conflicting medical evidence in similar cases involving the state's mining workforce.
