Peabody Coal Co. v. Director, Office of Workers' Compensation Programs, 718 F.3d 590

Brigance, a long-time coal miner, stopped work in 1994 due to shortness of breath from pneumoconiosis and later sought state benefits.
In 2001 Brigance filed a federal BLBA claim; at a 2004 hearing, he testified he had medical determinations of total disability from doctors in 1994/1995.
The ALJ held Brigance’s BLBA claim timely, noting the diagnosis had been communicated but not whether it was well-documented or well-reasoned, and awarded benefits.
The Board affirmed the ALJ, adopting a Kirk-based view that a reasoned opinion is required to trigger the statute.
Peabody Coal challenged timeliness and argued the statute runs when a medical determination is communicated, regardless of its documented reasoning.
This court reverses, holding that the statute’s trigger is simply the communicated medical determination; the well-reasoned/documented requirement is not imposed by statute or implementing regulation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must a medical determination be well-reasoned to trigger § 932(f)?	Brigance: require well-reasoned diagnosis to start clock.	Peabody: statute requires only communication of diagnosis.	No; only communication suffices; no requirement for well-reasoned diagnosis.
Does Dukes misdiagnosis concept affect timeliness where state benefits were awarded previously?	Brigance: Kentucky award and non-life-long benefits undermine timeliness.	Brigance waited seven years despite knowledge of diagnosis; rule not applicable.	Dukes rule not required; misdiagnosis not mandated to affect triggering here.

Kirk v. Tenn. Consol. Coal Co., 264 F.3d 602 (6th Cir. 2001) (reasoned opinion discussed; dicta not binding for well-reasoned requirement)
Arch of Ky., Inc. v. Dir., OWCP, 556 F.3d 472 (6th Cir. 2009) (medical diagnosis must come from trained medical professional)
Dukes v. Tenn. Consol. Coal Co., 48 F. App’x 140 (6th Cir. 2002) (misdiagnosis rule; clean slate if claim denied for disease absence)
Vill. of Milford v. K-H Holding Corp., 390 F.3d 926 (6th Cir. 2004) (statutes of limitations aim to prevent stale claims)
Duncan v. Walker, 533 U.S. 167 (Supreme Court 2001) (avoid rendering provisions superfluous; plain meaning rule)
Morrison v. Tenn. Consol. Coal Co., 644 F.3d 473 (6th Cir. 2011) (legal standards for BLBA limitations reviewed de novo)
Conley v. Nat’l Mines Corp., 595 F.3d 297 (6th Cir. 2010) (legal standard review of statutory interpretations)
Black Diamond Coal Mining Co. v. Dir., OWPC, 95 F.3d 1079 (11th Cir. 1996) (de novo review of BLBA limitations interpretations)
Dukes v. Tenn. Consol. Coal Co., 48 F. App’x 140 (6th Cir. 2002) (see above (misdiagnosis rule) )