U.S. Steel Mining Company, LLC v. Director, OWCP
719 F.3d 1275
11th Cir.2013Background
- Eligah Starks (miner) received a black-lung benefits award in 2000 and died in 2006; his widow Kathy Starks filed for survivor benefits in 2006 and sought modification in 2009.
- Under post-1981 law survivors generally had to file a claim and prove the miner’s death was caused by pneumoconiosis to receive benefits; 1977 law had earlier allowed survivors to continue an awarded miner’s benefits without refiling.
- The Affordable Care Act (ACA) §1556(b) (2010) restored 30 U.S.C. §932(l) to the pre-1981 text, eliminating the general requirement that eligible survivors file a new claim to continue benefits the miner was already receiving at death.
- ACA §1556(c) made the amendment retroactive to “claims filed…after January 1, 2005, that [were] pending on” March 23, 2010; Kathy’s survivor claim was pending on that date and was filed after Jan 1, 2005.
- The Department of Labor Benefits Review Board and the district court held §932(l) as amended: (1) permits survivors who meet relational/dependency criteria and show the miner was receiving benefits at death to receive benefits without proving cause of death; (2) applies retroactively to survivor claims filed in the §1556(c) window; and (3) its retroactive application does not violate due process.
Issues
| Issue | Plaintiff's Argument (Starks) | Defendant's Argument (U.S. Steel) | Held |
|---|---|---|---|
| Whether amended §932(l) eliminates survivor’s burden to prove miner’s cause of death | §932(l) removes the cause-of-death requirement for survivors who meet §932(l) conditions | §932(l) must be read with §§901/921/922, which still condition survivor benefits on miner’s death from pneumoconiosis | Held: §932(l) reasonably reads to entitle "eligible survivors" (those meeting relationship/dependency rules) to benefits if miner was receiving benefits at death; such survivors need not prove cause of death |
| Whether ACA §1556(c) retroactivity window covers survivors’ claims (versus only miners’ claims) | §1556(c) applies to any "claims" (miners or survivors) filed after Jan 1, 2005 and pending on Mar 23, 2010; Kathy’s claim qualifies | §1556(c) should be read to reference miners’ claims only, so Kathy (miner’s claim filed 1998) cannot benefit | Held: "claims" in §1556(c) covers survivors’ claims filed in the period; Kathy’s claim (filed after Jan 1, 2005 and pending) is covered |
| Whether retroactive application of §932(l) violates the Due Process Clause | Retroactivity is justified by Congress’ legitimate purpose to ease survivors’ burdens and compensate dependents; line-drawing is legislative prerogative | Retroactive application lacks a rational legislative purpose and the Jan 1, 2005 cutoff is arbitrary | Held: Retroactive application is supported by a rational legislative purpose and the cutoff is not arbitrary; due process challenge fails |
Key Cases Cited
- B & G Constr., Co. v. Dir., Off. of Workers' Comp. Programs, 662 F.3d 233 (3d Cir. 2011) (interpreting amended §932(l) to relieve survivors of cause-of-death showing)
- W. Va. CWP Fund v. Stacy, 671 F.3d 378 (4th Cir. 2011) (agreeing that amended §932(l) eliminates cause-of-death requirement for eligible survivors)
- Vision Processing, LLC v. Groves, 705 F.3d 551 (6th Cir. 2013) (concluding survivors still must prove miner’s death was due to pneumoconiosis)
- Pothering v. Parkson Coal Co., 861 F.2d 1321 (3d Cir. 1988) (construing the 1981 amendment’s reference to "claim" as referring to miners’ claims for retroactivity purposes)
- Pension Benefit Guaranty Corp. v. R.A. Gray & Co., 467 U.S. 717 (1984) (retroactive legislation meets due process if supported by a legitimate legislative purpose and rational means)
- United States v. Gonzales, 520 U.S. 1 (1997) (statutory interpretation begins with the text)