Decided: May 1, 2014
The Fourth Circuit determined that physicians’ opinions provided sufficient evidence that a coal miner’s lung disease hastened his death. Accordingly, the Court reversed and remanded the administrative board’s decision.
Johnnie Collins (“Collins”) was a coal miner that contracted Chronic Obstructive Pulmonary Disease (“COPD”) after working in the mines. He successfully obtained benefits under the Black Lung Benefits Act (the “Act”) until his death in 1997. His wife applied for survivor benefits under the Act and received them until 2012, when they were denied by an administrative board for insufficient evidence showing that Collins died from his lung disease, rather than from smoking. Collin’s wife appealed that decision to the Fourth Circuit.
Collin’s treating physician had compiled a multitude of notes that showed the seriousness of Collin’s lung condition, and laid out the details of Collin’s final weeks in a letter to the Department of Labor. Another physician stated that in his opinion Collin’s lung disease caused his death, after a review of the case file, death certificate, and additional hospital records. All of this evidence was sufficient to show that Collin’s lung disease hastened his death.