Case Explained: BLUFF SPUR COAL CORPORATION v. DIRECTOR, OFFICE OF WORKERS’ COMPENSATION PROGRAMS UNITED STATES DEPARTMENT OF LABOR; FREDERICK B. BATEMAN

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-04 The fourth-circuit denied Bluff Spur Coal Corporation’s petition for review of the Benefits Review Board’s order affirming an Administrative Law Judge’s award of black lung benefits to Frederick Bateman. Applying a deferential standard of review to determine whether factual findings are supported by substantial evidence and in accordance with the law, the court held that the ALJ’s finding that Bateman was totally disabled was supported by substantial evidence because the ALJ properly identified relevant evidence, resolved material conflicts, and adequately explained why certain physician opinions were credited over others. Additionally, the court affirmed the ALJ’s finding that Bateman was a never smoker, noting that the ALJ did not reweigh conflicting evidence or make credibility determinations but rather credited Bateman’s credible testimony regarding his smoking history. The practical consequence is that the Benefits Review Board’s decision and the underlying award of benefits remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.