Case Explained: JEFFBOAT, INC. and AMERICAN LONGSHORE MUTUAL ASSOCIATION, LTD v. DIRECTOR, OFFICE OF WORKERS’ COMPENSATION PROGRAMS United States Department of Labor, and CALVIN F. CHAFFERS

Court: United States Court of Appeals for the Seventh Circuit Filed: 2026-06-23 The Seventh Circuit affirmed the Benefits Review Board’s order awarding workers’ compensation benefits and attorneys’ fees to Calvin Chaffers under the Longshore and Harbor Workers’ Compensation Act (LHWCA). The court held that the Administrative Law Judge’s (ALJ) findings were rational, supported by substantial evidence, and consistent with governing law. The court applied the deferential “substantial evidence” standard of review, which requires only that relevant evidence be sufficient for a reasonable mind to accept as adequate to support a conclusion, rather than requiring a preponderance of the evidence or allowing the court to reweigh conflicting testimony. Under the LHWCA’s burden-shifting framework in 33 U.S.C. § 920(a), the claimant must first establish a prima facie case showing harm and workplace conditions capable of causing that harm, which triggers a presumption of work-relatedness. The employer may rebut this presumption with substantial evidence to the contrary, shifting the burden back to the claimant to prove causation by a preponderance of the evidence based on the record as a whole. The court found Chaffers satisfied his initial burden through testimony and medical records from treating and expert physicians diagnosing pulmonary conditions such as COPD and emphysema, noting that even Jeffboat’s own expert acknowledged the chemicals involved could cause lung disease. Although the employer successfully rebutted the presumption by arguing the symptoms were likely cardiac or unrelated, the ALJ properly resolved the conflict in favor of Chaffers’ expert, Dr. Gupta, whose opinion was more thoroughly explained and supported by medical literature compared to Dr. Frazier’s failure to explain why the acknowledged irritants did not cause harm in this specific case. The court further ruled that Chaffers did not need to prove a specific disease label or total inability to work to qualify for permanent partial disability benefits, as the Act covers any physical harm resulting from employment and allows for partial impairment ratings based on the AMA Guides. Additionally, the court dismissed Jeffboat’s challenge to the attorneys’ fees award as waived due to the failure to provide necessary record materials and legal citations. Consequently, the petition for review is denied, and the lower agency decisions awarding Chaffers permanent partial disability benefits and reduced attorneys’ fees remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.