Oak Grove Resources, Llc, Et Alv.Director, Owcp, Et Al
These consolidated appeals concerned survivors’ entitlement to benefits under the Black Lung Benefits Act. One mining company challenged an administrative law judge’s finding that a former miner qualified for benefits. The central issue was whether the Act’s automatic-entitlement provision required a formal government determination of eligibility before the miner’s death, or instead required only that the miner was eligible at death. The Eleventh Circuit affirmed the Benefits Review Board. Reading the statutory text, the court held that the phrase at the time of his or her death modified eligible, not determined. A survivor could therefore qualify when the miner met the eligibility requirements before death even if the formal determination came later. The court also rejected the employer’s substantial-evidence challenges and found the legislative history unhelpful compared with the enacted text. The published decision is notable for resolving an important statutory question affecting survivors of miners and for emphasizing text-based interpretation in a complex benefits scheme.
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