CINCINNATI, OH – The U.S. Court of Appeals for the Sixth Circuit has denied a petition from the Cumberland River Coal Company, which sought to overturn an award of federal black lung benefits granted to retired Kentucky coal miner Carlos Sturgill.
Sturgill, a former underground miner with more than 25 years of experience, retired in 2007 after suffering a heart attack in the mines. He later underwent open-heart surgery and experienced chronic respiratory issues including shortness of breath, wheezing, and bronchitis. After his initial claim for benefits under the Black Lung Benefits Act (BLBA) was denied in 2016, Sturgill submitted new medical evidence in a 2018 claim that led to an award of benefits.
The BLBA allows coal miners to collect benefits if they develop a respiratory disability caused by pneumoconiosis, a disease linked to coal mine dust exposure. Under a 2010 amendment to the law, miners who worked underground for at least 15 years and have a disabling respiratory condition are presumed to suffer from pneumoconiosis unless rebutted by the employer.
Cumberland challenged the benefits award, arguing that the Administrative Law Judge (ALJ) improperly evaluated expert medical testimony. However, the Sixth Circuit upheld the ALJ’s credibility determinations, finding they were supported by substantial evidence.
The ALJ gave significant weight to testimony from Dr. Mahmood Alam, who found that Sturgill had a disabling pulmonary condition supported by blood gas testing. The court found that Dr. Alam’s reasoning, including his explanation for varying test results, provided a valid basis for the ALJ’s decision.
In contrast, the ALJ gave less weight to opposing testimony from Dr. Abdul Dahhan and Dr. David Rosenberg, who failed to reconcile contradictory medical evidence or adequately explain how Sturgill could return to his former physically demanding mining work.
The court also rejected Cumberland’s argument that benefits should not have started in June 2018, the month Sturgill filed his claim. The court found that contradictory evidence did not preclude the ALJ from awarding benefits from that date.
The case is Cumberland River Coal Co. v. Director, OWCP, et al., No. 25-3080.
