Grayson Coal & Stone Co. v. Charles Teague
688 F. App'x 331
| 6th Cir. | 2017Background
- Claimant Charles R. Teague worked ~9.22 years in Kentucky coal mining and filed a black lung claim in 2010; an ALJ awarded benefits in 2014 and the Benefits Review Board affirmed.
- To obtain benefits under the Black Lung Benefits Act a miner must prove pneumoconiosis, that it arose from coal-mine employment, total disability, and that pneumoconiosis contributes to the disability.
- Five physicians submitted opinions: Drs. Habre, Forehand, Gallai, Broudy, and Rosenberg; three diagnosed pneumoconiosis (including Habre) and two diagnosed smoking-related COPD.
- The ALJ found Teague had smoked “for a substantial amount of time” but declined to fix an exact pack-year figure due to inconsistent records.
- The ALJ gave greatest weight to Dr. Habre’s opinion as "well‑reasoned" and based on objective testing, and discounted other physicians’ opinions for specific deficiencies, concluding legal pneumoconiosis was a substantially contributing cause of disability.
- Grayson Coal and Liberty Mutual appealed, arguing (1) the ALJ failed to make a specific factual finding on smoking history and (2) Dr. Habre’s opinion was not supported by substantial evidence. The Sixth Circuit affirmed the Board.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Specificity of smoking-history finding | Grayson: APA required an exact finding (years/pack‑years); without it the record lacks reasoned basis. | Teague: ALJ reasonably concluded claimant smoked a substantial time and analyzed inconsistencies; exact figure not required. | Court: ALJ did not err; a specific pack‑year finding was unnecessary and might have misstated contradictory evidence; analysis was sufficiently reasoned. |
| Reliance on Dr. Habre’s opinion | Grayson: ALJ improperly credited Habre; Habre’s opinion lacked substantial evidentiary support. | Teague/Board: ALJ permissibly weighed medical opinions, explained why Habre was well‑reasoned, and discounted other reports for stated defects. | Court: ALJ’s credibility determinations and reliance on Habre were supported by substantial evidence and adequately explained; decision affirmed. |
Key Cases Cited
- Big Branch Res., Inc. v. Ogle, 737 F.3d 1063 (6th Cir. 2013) (standard for reviewing ALJ medical-evidence credibility in black lung cases)
- Cumberland River Coal Co. v. Banks, 690 F.3d 477 (6th Cir. 2012) (appellate review limited to legal errors and substantial‑evidence inquiry)
- Peabody Coal Co. v. Groves, 277 F.3d 829 (6th Cir. 2002) (deference to ALJ’s evaluation of whether a physician’s opinion is sufficiently reasoned and documented)
- Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (definition of substantial evidence)
- Peabody Coal Co. v. Hill, 123 F.3d 412 (6th Cir. 1997) (narrow scope of review where ALJ weighed conflicting medical evidence)
- Neace v. Dir., Office of Workers’ Comp. Programs, 867 F.2d 264 (6th Cir. 1989) (court will uphold ALJ conclusion supported by substantial evidence even if it might reach a different view)
- Buck Creek Coal Co. v. Sexton, 706 F.3d 756 (6th Cir. 2013) (miners may file subsequent claims due to pneumoconiosis’ latent and progressive nature)