Judge Arianna Freeman, who was nominated by President Biden to the Third Circuit court of appeals, wrote a unanimous opinion that upheld a Department of Labor award of Black Lung benefits to a retired coal worker, rejecting claims by his coal company employer. The September 2024 decision was in Consolidated Pennsylvania Coal Co v Director, OWCP.
What happened in this case? ,
Stephen Hela worked as an underground coal miner for more than 13 years, requiring heavy lifting as well as exposure to coal dust. His last employer was Consolidated Pennsylvania Coal Co. He applied to the Department of Labor for disability benefits under the federal Black Lung Benefits Act.
After a hearing, an Administrative Law Judge (ALJ) concluded that Hela had black lung disease and was totally disabled and entitled to benefits, with doctors explaining that he had obstructive lung disease, chronic bronchitis, and chronic obstructive pulmonary disease. The Labor Department’s Benefit Review Board agreed. By that time, Hela had died, and the benefits would go to Hela’s family. But Consolidated disagreed with the review board, and took the case to the Third Circuit for review.
How did Judge Freeman and the Third Circuit Rule and Why is it Important?
Judge Freeman’s unanimous opinion upheld the Labor Department’s determination. Although Consolidated pointed to some physician and related evidence that suggested Hela had asthma and not black lung disease, Judge Freeman found that the ALJ had carefully evaluated and weighed all the evidence in the record. In accordance with precedent, she concluded that “substantial evidence” supported the ALJ’s finding and “there is no basis to disturb it.”
Judge Freeman’s opinion is obviously important to the family of Stephen Hela, who will now receive his Black Lung benefits. It also provides an example of a court rejecting a coal company attack on a black lung benefits determination that may be helpful in other cases, particularly in the Third Circuit, which includes Pennsylvania, New Jersey, and Delaware. In addition, the decision serves as a reminder of the importance of promptly confirming fair-minded judges to our federal courts.