Island Creek Coal Company Petition Denied - Black Lung Benefits

4th Circuit Daily Opinions

Filed February 18th, 2026

Detected February 19th, 2026

Summary

The Fourth Circuit Court of Appeals denied Island Creek Coal Company's petition for review of a Benefits Review Board decision. The Board had affirmed an Administrative Law Judge's denial of black lung benefits. The court found the Board's decision was based on substantial evidence and without reversible error.

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What changed

The Fourth Circuit Court of Appeals has denied the petition for review filed by Island Creek Coal Company. The petition sought to overturn a decision by the Benefits Review Board (BRB), which had affirmed an Administrative Law Judge's (ALJ) denial of black lung benefits. The court's decision, made per curiam, found that the BRB's decision was supported by substantial evidence and contained no reversible legal errors, referencing the specific BRB case number 23-0242 BLA.

This denial means that the ALJ's original decision to deny black lung benefits stands. For regulated entities, particularly coal companies, this reinforces the standard of review for black lung benefit claims and the importance of substantial evidence in supporting factual findings. As this is an unpublished opinion, it does not set binding precedent in the Fourth Circuit, but it confirms the outcome for this specific petitioner. No new compliance actions are mandated by this ruling.

Source document (simplified)

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 24 - 1721 ISLAND CREEK COAL COM PANY, Petitioner, v. DIRECTOR, OFFICE OF WORKERS ’ COMPENSAT ION PROGRA MS, UNITED ST ATES DEPARTM ENT OF LAB OR; ROGER D. YATES, Respondents. On Petition for Rev iew of an Order of the Benefit s Review Board. (23 - 0242 BLA) Submitted: January 21, 2026 Decided: February 18, 2026 Before RICHARDS ON, QUATTLEB AUM, and HEYTENS, Circuit Judges. Pet ition denied by unpublishe d per curiam opinion. ON BRIEF: Joh n R. Sigmo nd, PENN, S TUART & E SKRIDGE, Bristol, Tennessee, for Petitioner. Brad A. A ustin, WOLFE WILLIAMS & AUS TIN, Norton, Virginia, for Respondent Roger D. Y ates. Unpublished opinions are not binding p recedent in this circuit.

2 PER CURIAM: Island Creek Coal Company petitions for review of the Benefits Review Board ’s (BRB) decision and order affirming th e A dministrative L aw J udge ’s (ALJ) denial of black lung bene fits pursua nt to 30 U. S.C. §§ 901 - 94 4. Our review of the BRB’s decision is limited to considering “whether substantial evid ence supports the factual finding s of the ALJ and whether the legal conclusions of the [BRB] and ALJ are rational and consistent with applicable law.” Westmoreland Coa l Co. v. Stallard, 876 F.3d 663, 6 68 (4th Cir. 2017) (internal quotation marks omitted). “Substantial evidence is more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Sea “B” Mining Co. v. Addi son, 831 F.3 d 244, 252 (4th C ir. 2016) (internal quotation marks omitted). “To determine whether this standard has been met, we consider whether all of the relevant evidence has been analyzed and whether the ALJ has sufficiently explain ed his rationale in crediting certain evidence.” Ho bet Mining, LLC v. Epli ng, 783 F.3d 498, 504 (4th Cir. 2015) (internal quotation marks omitted). Our review of the record discloses that the B RB ’s decision is based upon substantial evidence and is without reversible error. Accordingly, we deny the petitio n for review for the reasons stated by the B RB. BRB - 1: 23 - 0242 BLA. We dispense with oral argument because the facts and legal contentions are adequately presented in th e materials before this court and argument would no t aid the decisional process. PETITION DENIE D