Antelope Coal Co./Rio Tinto Energy America v. Goodin
743 F.3d 1331
10th Cir.2014Background
- Goodin worked 25 years in surface coal mines and developed a respiratory condition.
- He applied for BLBA benefits; ALJ awarded benefits; Antelope Coal Company appealed.
- The Benefits Review Board affirmed; Antelope sought judicial review under 33 U.S.C. § 921(a).
- Antelope challenged the applicability of the Final Rule and the rebuttal standards under § 718.305.
- The court held the Final Rule applies and affirmed the ALJ’s award of benefits to Goodin.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Final Rule applies to this case. | Antelope: Final Rule applies retroactively to limit rebuttal. | Goodin: Final Rule clarifies existing law and applies here. | Final Rule applies to this case. |
| Whether Goodin is entitled to the 15-year presumption. | Antelope contends insufficient similarity and disability evidence rebutting presumption. | Goodin satisfies 15 years and total disability; presumption stands. | Yes; Goodin entitled to the 15-year presumption. |
| Whether Antelope could rebut the presumption under the rebuttal limitations. | Antelope argues limitations do not apply to operators or restrict rebuttal. | Goodin: limitations apply and Antelope failed to rebut. | Antelope failed to rebut under the limitations; harmless error if any. |
| Whether the ALJ properly applied the substantial-similarity standard to surface mining conditions. | Antelope: surface mining conditions not substantially similar; traditional standard applies. | Goodin: revised 718.305(b)(2) requires regular exposure to coal dust; evidence supports similarity. | There was substantial evidence of regular dust exposure making surface conditions substantially similar. |
| Whether the ALJ adequately considered all medical evidence and the completeness of the pulmonary exam. | Antelope: exam/readings were unreadable or incomplete; evidence was ignored. | ALJ considered substantial medical evidence; need not discuss every piece. | No reversible error; substantial evidence supports the decision. |
Key Cases Cited
- Energy West Mining Co. v. Oliver, 555 F.3d 1211 (10th Cir. 2009) (standard of review: substantial evidence)
- Mangus v. Dir., OWCP, 882 F.2d 1527 (10th Cir. 1989) (de novo review of law; agency interpretation respected)
- Andersen v. Dir., OWCP, 455 F.3d 1102 (10th Cir. 2006) (give substantial weight to agency’s interpretation of regulations)
- Usery v. Turner Elkhorn Mining Co., 428 U.S. 1 (U.S. 1976) (rebuttal limitations apply only to the Secretary, not operators)
- Island Creek Ky. Mining v. Ramage, 737 F.3d 1050 (6th Cir. 2013) (disability causation can be adequately supported by substantial evidence)
- Mingo Logan Coal Co. v. Owens, 724 F.3d 550 (4th Cir. 2013) (rebuttal limitations context for employers)