Sequoia Energy, LLC v. Amy Mitchell

── Sequoia Energy, LLC v. Amy Mitchell ── Court: Court of Appeals for the Sixth Circuit Date: April 28, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0188n.06 No. 25-3451 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Apr 28, 2026 SEQUOIA ENERGY, LLC; NATIONAL UNION ) KELLY L. STEPHENS, Clerk ) FIRE/AIG, ) Petitioners, ) ) ON PETITION FOR REVEIW v. ) FROM THE BENEFITS ) REVIEW BOARD AMY MITCHELL; DIRECTOR, OFFICE OF ) WORKERS’ COMPENSATION PROGRAMS, U.S. ) OPINION DEPARTMENT OF LABOR, ) Respondents. ) ) Before: READLER, DAVIS, and BLOOMEKATZ, Circuit Judges. BLOOMEKATZ, Circuit Judge. Sequoia Energy, LLC petitions for review of a Benefits Review Board decision affirming the award of federal coal miners’ benefits to now-deceased miner Delbert Mitchell and his surviving spouse Amy Mitchell. But Sequoia has not rebutted the presumption that Mitchell was entitled to benefits due to his over 15 years of work in coal mines and total pulmonary disability. So we deny the petition for review. Mitchell worked for at least 22 years in an underground coal mine. A substantial portion of that work was in Sequoia’s employ. In Mitchell’s last role, he worked as a maintenance foreman, crawling in the mines for over six hours a day and lifting up to 100 pounds. Mitchell stopped working as a coal miner in 2015, based on a diagnosis of chronic obstructive pulmonary disease. An examining doctor would later find that Mitchell’s “pulmonary impairment” was “very severe.” AR 170. No. 25-3451, Sequoia Energy, LLC, et al. v. Mitchell, et al. Mitchell filed a claim for benefits under the Black Lung Benefits Act in 2019. The Act provides federal benefits to qualifying coal miners and their survivors. 30 U.S.C. §§ 901, 932(l). Eligibility for benefits turns on a miner’s pneumoconiosis, which the Act defines as “a chronic dust disease of the lung and its sequelae, including respiratory and pulmonary impairments, arising out of coal mine employment.” Id. § 902(b). Specifically, to receive benefits, Mitchell was required to show four facts: (1) he was “totally disabled”; (2) he had pneumoconiosis; (3) his pneumoconiosis “arose out of [his] coal mine employment”; and (4) his pneumoconiosis “contribute[d]” to his total disability. Island Creek Coal Co. v. Wilkerson, 910 F.3d 254, 257 (6th Cir. 2018) (quoting 20 C.F.R. § 725.202(d)(2)). We note that because the definition of pneumoconiosis provides that the disease “aris[es] out of coal mine employment,” 30 U.S.C. § 902(b), the second and third elements often overlap. See Arch on the Green, Inc. v. Groves, 761 F.3d 594, 597–98 (6th Cir. 2014). Mitchell’s claim invoked a powerful burden-shifting mechanism sometimes referred to as the “fifteen-year presumption.” See Incoal, Inc. v. Dir., Off. of Workers’ Comp. Programs, U.S. Dep’t of Lab., 123 F.4th 808, 814 (6th Cir. 2024). The presumption provides that if a miner shows they were “employed for fifteen years or more” in a qualifying mine and “demonstrates the existence of a totally disabling respiratory or pulmonary impairment,” there is “a rebuttable presumption” that the “miner is totally disabled due to pneumoconiosis.” 30 U.S.C. § 921(c)(4); 20 C.F.R. § 718.305. In other words, once a miner with sufficient qualifying work proves they have a total