Pocahontas Coal Company, LLC v. DOWCP

CourtCourt of Appeals for the Fourth Circuit
DecidedJuly 10, 2026
Docket25-1369
StatusUnpublished

This text of Pocahontas Coal Company, LLC v. DOWCP (Pocahontas Coal Company, LLC v. DOWCP) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pocahontas Coal Company, LLC v. DOWCP, (4th Cir. 2026).

Opinion

USCA4 Appeal: 25-1369 Doc: 33 Filed: 07/10/2026 Pg: 1 of 7

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-1369

POCAHONTAS COAL COMPANY, LLC; BRICKSTREET/ENCOVA MUTUAL INSURANCE,

Petitioners,

v.

DIRECTOR, OFFICE OF WORKERS’ COMPENSATION PROGRAMS, UNITED STATES DEPARTMENT OF LABOR; RONNIE L. WOLFORD,

Respondents.

On Petition for Review of an Order of the Benefits Review Board. (24-0266 BLA)

Submitted: April 13, 2026 Decided: July 10, 2026

Before GREGORY, WYNN, and RUSHING, Circuit Judges.

Petition denied by unpublished per curiam opinion.

ON BRIEF: Joseph D. Halbert, HALBERT LEGAL, PLLC, Lexington, Kentucky, for Petitioner. Brad A. Austin, WOLFE WILLIAMS & AUSTIN, Norton, Virginia, for Respondent Ronnie L. Wolford.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-1369 Doc: 33 Filed: 07/10/2026 Pg: 2 of 7

PER CURIAM:

Pocahontas Coal Company, LLC (“Pocahontas Coal”), petitions this Court for

review of the Benefits Review Board’s decision and order affirming the administrative law

judge’s award of benefits to Ronnie Wolford under the Black Lung Benefits Act, 30 U.S.C.

§§ 901–945. We deny the petition for review.

I.

Wolford filed his initial claim for black lung benefits in October 2018. The District

Director issued a Proposed Decision and Order awarding benefits. Pocahontas Coal

disputed the proposed award and requested a hearing before an administrative law judge

(“ALJ”).

After reviewing the evidence, including testimony from Wolford, the ALJ issued a

decision and order awarding benefits. The ALJ found that Wolford had at least 15 years or

more of qualifying coal mine employment. The ALJ then found that Wolford had a totally

disabling impairment, as supported by arterial blood-gas studies and medical opinion

evidence. 1 Thus, the ALJ found that Wolford could invoke the 15-year presumption of total

disability. See 30 U.S.C. § 921(c)(4); 20 C.F.R. § 718.305. Finally, the ALJ found that

Pocahontas Coal had failed to rebut that presumption and awarded benefits to Wolford.

1 To establish total disability, a miner can submit four types of medical evidence: “(1) qualifying pulmonary function tests . . . , (2) qualifying arterial blood-gas studies . . . , (3) a showing that he has pneumoconiosis and suffers from cor pulmonale with right-sided congestive heart failure, or (4) well-documented and well-reasoned physician’s opinions concluding that the miner’s respiratory or pulmonary condition prevents him from engaging in his last mining job and similar work.” Island Creek Coal Co. v. Blankenship, 123 F.4th 684, 688–89 (4th Cir. 2024).

2 USCA4 Appeal: 25-1369 Doc: 33 Filed: 07/10/2026 Pg: 3 of 7

On appeal, the Benefits Review Board (“the Board”) concluded that the ALJ did not

adequately explain her findings regarding total disability. The ALJ had given three arterial

blood-gas studies equal weight and summarily concluded that the preponderance of the

evidence supported a finding of total disability. 2 The three studies produced, respectively,

(1) non-qualifying values at rest, but qualifying values during exercise; (2) qualifying

values during rest (and thus no exercise test was performed); and (3) non-qualifying values

at rest and during exercise. 3 The Board vacated the ALJ’s determination of total disability

and remanded for the ALJ to explain how she had resolved the conflicts between the

studies, noting that an ALJ must weigh the quality of the evidence in addition to its

quantity.

On remand, the ALJ reconsidered the studies and found that the study that had

resulted in non-qualifying values at rest and during exercise (study (3) above) should be

2 There was a fourth arterial blood-gas study that resulted in a non-qualifying value at rest. However, the ALJ gave that study little probative weight because it did not comply with a requirement under 20 C.F.R. § 718.105(b) to perform an exercise test, absent medical contraindications, after a non-qualifying resting test. See, e.g., Lane v. Union Carbide Corp., 105 F.3d 166, 173 (4th Cir. 1997). Pocahontas Coal argues that the ALJ should not have discredited the resting test. We disagree. We have held that “it is appropriate to give little weight to medical findings that conflict with the Black Lung Act’s implementing regulations.” Extra Energy, Inc. v. Lawson, 140 F.4th 138, 147 (4th Cir. 2025) (cleaned up). 3 Arterial blood-gas studies “produce numeric values and the Department of Labor has promulgated tables identifying which values indicate that a miner is totally disabled.” Island Creek Coal, 123 F.4th at 689 n.2 (citing 20 C.F.R. § 718.204(b)(2)). “When the values produced by a [study] meet the values listed in those tables a miner is totally disabled, and the test is referred to as ‘qualifying.’” Id. The test is initially administered at rest. 20 C.F.R. § 718.105(b). If the resting results are qualifying, the study may end, but non-qualifying results require a subsequent test during exercise “unless medically contraindicated.” Id.

3 USCA4 Appeal: 25-1369 Doc: 33 Filed: 07/10/2026 Pg: 4 of 7

ascribed lesser weight than the study that had resulted in non-qualifying values at rest but

qualifying values during exercise (study (1) above). That finding was based on a difference

between the length of the exercise portion: The former lasted three minutes and 23 seconds,

while the latter lasted five minutes. A longer test, the ALJ reasoned, was more indicative

of Wolford’s ability to perform in his last coal mine employment. The ALJ found that this

greater weight accorded to the qualifying exercise study, combined with the study that

resulted in a qualifying value at rest (study (2) above), supported a finding of total

disability. 4

On appeal, the Board affirmed in a split decision. The Board rejected Pocahontas

Coal’s argument that the ALJ impermissibly gave lesser weight to the shorter exercise

study, concluding that the ALJ had complied with its remand instructions to adequately

explain the weight she accorded the conflicting evidence. The dissent found merit in

Pocahontas Coal’s argument, however, and would have concluded that only those with

medical knowledge could review the two exercise studies and evaluate their relative

strenuousness.

Pocahontas Coal petitioned this Court for review.

4 The ALJ also found that medical opinion evidence supported a finding of total disability. Pocahontas Coal challenges this analysis as flawed because it derived from the ALJ’s allegedly flawed assessment of the arterial blood-gas study evidence. Because we conclude that the ALJ properly assessed the arterial blood-gas study evidence, this claim fails.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Pocahontas Coal Company, LLC v. DOWCP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pocahontas-coal-company-llc-v-dowcp-ca4-2026.