6th Circ. Erases Peabody Coal Worker's Black Lung Award

Law360, New York (June 10, 2013, 4:52 PM EDT) -- The Sixth Circuit on Monday reversed a Black Lung Benefits Act award to a former Peabody Coal Co. worker who waited seven years to file a claim, saying the statutory limitation period does not require a triggering diagnosis to be well-reasoned and fully documented.

A three-judge panel upended an administrative law judge's holding that the BLBA's three-year statute of limitations did not bar Virgil Brigance from making a delayed benefits claim on the grounds the absence of medical documents showing he had total disability from pneumoconiosis...
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