Star Servs. Corp. v. OWCP

── Star Servs. Corp. v. OWCP ── Court: Court of Appeals for the Sixth Circuit Date: April 17, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0173n.06 No. 25-3517 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Apr 17, 2026 KELLY L. STEPHENS, Clerk ) STAR SERVICES CORPORATION, et al., ) Petitioners, ) ON PETITION FOR REVIEW ) FROM THE BENEFITS REVIEW v. ) BOARD ) OWCP, et al., ) OPINION Respondents. ) ) Before: CLAY, McKEAGUE, and NALBANDIAN, Circuit Judges. CLAY, Circuit Judge. Respondent Linda Carol Christian, the widow of coal miner James Marshall Christian, filed a claim for benefits under the Black Lung Benefits Act, 30 U.S.C. § 901 et seq., against Petitioner Star Services Corporation, insured through Petitioner Birmingham Fire Insurance/AIG. The administrative law judge determined that Respondent Linda Carol Christian was entitled to benefits, and the Benefits Review Board affirmed that decision. Petitioners Star Services Corporation and Birmingham Fire Insurance/AIG now seek our review of the award of benefits. For the reasons set forth below, we DENY the petition for review and AFFIRM the award of benefits. I. BACKGROUND A. Statutory Framework The Black Lung Benefits Act (“BLBA”) provides “benefits to coal miners who are totally disabled due to pneumoconiosis and to the surviving dependents of miners whose death was due to such disease.” Shepherd v. Incoal, Inc., 915 F.3d 392, 399 (6th Cir. 2019) (cleaned up). -1- No. 25-3517, Star Services Corporation, et al. v. OWCP, et al. Pneumoconiosis is “a chronic dust disease of the lung and its sequelae, including respiratory and pulmonary impairments, arising out of coal mine employment.” 30 U.S.C. § 902(b). “The BLBA provides benefits based on two forms of pneumoconiosis: (1) clinical pneumoconiosis, and (2) legal pneumoconiosis.” Island Creek Coal Co. v. Maynard ex rel. Maynard, 87 F.4th 802, 807 (6th Cir. 2023). Clinical pneumoconiosis comprises “a specific set of enumerated diseases” recognized by the medical community, whereas “legal pneumoconiosis is a broader and less definite term that refers to any chronic lung disease that was caused in this instance by exposure to coal-mine dust.” Brandywine Explosives & Supply v. Dir., Off. of Workers’ Comp. Programs, 790 F.3d 657, 661 (6th Cir. 2015) (citation modified); see also 20 C.F.R. § 718.201(a). To establish benefits under the BLBA, a surviving spouse must prove that the “miner had pneumoconiosis” that “arose out of coal mine employment” and that “the miner’s death was due to pneumoconiosis.” 20 C.F.R. § 718.205(a); Conley v. Nat’l Mines Corp, 595 F.3d 297, 302 (6th Cir. 2010). If the miner worked in underground coal mining for at least fifteen years and the evidence demonstrates that he had “a totally disabling respiratory or pulmonary impairment” at the time of his death, it is presumed that pneumoconiosis caused the miner’s death. 20 C.F.R. § 718.305(b)(1), (c)(2); Island Creek Coal Co. v. Hunt, 730 F. App’x 367, 368 (6th Cir. 2018). Once a claimant establishes this fifteen-year presumption, “the burden shifts to th