Star Servs. Corp. v. OWCP

CourtCourt of Appeals for the Sixth Circuit
DecidedApril 17, 2026
Docket25-3517
StatusUnpublished

This text of Star Servs. Corp. v. OWCP (Star Servs. Corp. v. OWCP) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Star Servs. Corp. v. OWCP, (6th Cir. 2026).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 26a0173n.06

No. 25-3517

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Apr 17, 2026 KELLY L. STEPHENS, Clerk ) STAR SERVICES CORPORATION, et al., ) Petitioners, ) ON PETITION FOR REVIEW ) FROM THE BENEFITS REVIEW v. ) BOARD ) OWCP, et al., ) OPINION Respondents. ) )

Before: CLAY, McKEAGUE, and NALBANDIAN, Circuit Judges.

CLAY, Circuit Judge. Respondent Linda Carol Christian, the widow of coal miner James

Marshall Christian, filed a claim for benefits under the Black Lung Benefits Act, 30 U.S.C. § 901

et seq., against Petitioner Star Services Corporation, insured through Petitioner Birmingham Fire

Insurance/AIG. The administrative law judge determined that Respondent Linda Carol Christian

was entitled to benefits, and the Benefits Review Board affirmed that decision. Petitioners Star

Services Corporation and Birmingham Fire Insurance/AIG now seek our review of the award of

benefits. For the reasons set forth below, we DENY the petition for review and AFFIRM the

award of benefits.

I. BACKGROUND

A. Statutory Framework

The Black Lung Benefits Act (“BLBA”) provides “benefits to coal miners who are totally

disabled due to pneumoconiosis and to the surviving dependents of miners whose death was due

to such disease.” Shepherd v. Incoal, Inc., 915 F.3d 392, 399 (6th Cir. 2019) (cleaned up).

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Pneumoconiosis is “a chronic dust disease of the lung and its sequelae, including respiratory and

pulmonary impairments, arising out of coal mine employment.” 30 U.S.C. § 902(b). “The BLBA

provides benefits based on two forms of pneumoconiosis: (1) clinical pneumoconiosis, and

(2) legal pneumoconiosis.” Island Creek Coal Co. v. Maynard ex rel. Maynard, 87 F.4th 802, 807

(6th Cir. 2023). Clinical pneumoconiosis comprises “a specific set of enumerated diseases”

recognized by the medical community, whereas “legal pneumoconiosis is a broader and less

definite term that refers to any chronic lung disease that was caused in this instance by exposure

to coal-mine dust.” Brandywine Explosives & Supply v. Dir., Off. of Workers’ Comp. Programs,

790 F.3d 657, 661 (6th Cir. 2015) (citation modified); see also 20 C.F.R. § 718.201(a).

To establish benefits under the BLBA, a surviving spouse must prove that the “miner had

pneumoconiosis” that “arose out of coal mine employment” and that “the miner’s death was due

to pneumoconiosis.” 20 C.F.R. § 718.205(a); Conley v. Nat’l Mines Corp, 595 F.3d 297, 302 (6th

Cir. 2010). If the miner worked in underground coal mining for at least fifteen years and the

evidence demonstrates that he had “a totally disabling respiratory or pulmonary impairment” at

the time of his death, it is presumed that pneumoconiosis caused the miner’s death. 20 C.F.R.

§ 718.305(b)(1), (c)(2); Island Creek Coal Co. v. Hunt, 730 F. App’x 367, 368 (6th Cir. 2018).

Once a claimant establishes this fifteen-year presumption, “the burden shifts to the

employer to rebut it.” Maynard ex rel. Maynard, 87 F.4th at 814. In a survivor’s claim, an

employer may rebut the presumption in two ways. Island Creek Coal Co. v. Bryan, 937 F.3d 738,

757 (6th Cir. 2019); 20 C.F.R. § 718.305(d)(2)(i)–(ii). For the first way, the employer “must show

that the miner did not have pneumoconiosis” by proving that the miner had neither legal

pneumoconiosis nor clinical pneumoconiosis. Bryan, 937 F.3d at 757-58; see also 20 C.F.R.

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§ 718.305(d)(2)(i). For the second way, the employer must establish “that no part of the miner’s

death was caused by pneumoconiosis.” 20 C.F.R. § 718.305(d)(2)(ii).

B. Factual Background

James Marshall Christian (“Christian”) worked underground as a coal miner for 30 years

between 1969 and 2001. Christian most recently worked for Petitioner Star Services Corporation

(“Star Services”). From 1965 to 1991, Christian smoked around one package of cigarettes per day.

By 2019, Christian struggled to breathe. Christian visited the emergency room on multiple

occasions to address his respiratory issues, used a CPAP machine at night, and eventually required

hospitalization and intubation for an extended period. Christian died while in the hospital on June

18, 2019.

Respondent Linda Carol Christian (“Claimant”) was married to Christian for 53 years and,

after his death, filed a claim for benefits under the BLBA on September 23, 2019. On October 5,

2023, the administrative law judge (“ALJ”) awarded benefits on the claim. The ALJ found that:

(1) Christian had over fifteen years of qualifying coal mine employment; (2) Christian “was totally

disabled by a respiratory impairment for at least two months before and at the time of his death”;

(3) because Christian had over fifteen years of underground coal mine employment and a totally

disabling respiratory impairment at the time of his death, Claimant invoked the fifteen-year

presumption that Christian’s death was due to pneumoconiosis; (4) Star Services failed to rebut

that presumption; and (5) Claimant was entitled to benefits under the BLBA on behalf of her

husband, Christian. ALJ Order, Page ID #0118-31. The Benefits Review Board (“Board”)

affirmed the ALJ’s award of benefits. Star Services petitioned this Court for review of the ALJ’s

decision.

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II. DISCUSSION

A. Standard of Review

“In reviewing an appeal from the Board, we review the Board’s legal conclusions de novo.”

Big Branch Res., Inc. v. Ogle, 737 F.3d 1063, 1068 (6th Cir. 2013). Although “we will not vacate

the Board’s decision unless it has committed a legal error or exceeded its scope of review, ‘our

review actually focuses on whether the ALJ’s decision is supported by substantial evidence.’”

Maynard ex rel. Maynard, 87 F.4th at 809 (quoting Island Creek Ky. Mining v. Ramage, 737 F.3d

1050, 1056 (6th Cir. 2013)). “An ALJ’s decision is supported by substantial evidence if ‘such

relevant evidence as a reasonable mind might accept as adequate’ supports the conclusion.” Id.

(quoting Ogle, 737 F.3d 1068-69). “If the ALJ has adequately explained why he weighed the

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