HOBET MINING V. HORACE K. MEREDITH, JR.
- Summarized by Danielle Scott , U.S. Bankruptcy Court, Southern District of West Virginia
- 4 months 3 weeks ago
- Case Type:
- Business
- Case Status:
- Reversed and Remanded
- Citation:
- 23-2157 (4th Circuit, Oct 01,2025) Published
- Tag(s):
-
- Ruling:
- The Fourth Circuit vacated the Department of Labor's Benefits Review Board decision. The Fourth Circuit held: (1) the Board erred in affirming the ALJ's conclusion that Arch was liable for Meredith's benefits because it insured Hobet. The previous self insurance did not create ongoing liability for black lung claims filed after Arch sold Hobet; and (2) the Board erred in concluding that Hobet was a responsible operator as it did not meet the three conditions to establish financial capability to pay benefits under 20 C.F.R. § 725.494(e).
- Procedural context:
- In 2019, Horace Meredith filed a claim for benefits under BLBA twenty years after his last employment with Hobet. The Department of Labor's district director identified Hobet as the responsible operator and Arch as Hobet's self insurer at the time of Meredith's employment in accordance with 20 C.F.R. § 725.350. Arch and Hobet requested a hearing before an ALJ who upheld the district director's decision. Arch appealed to the Benefits Review Board which affirmed the ALJ's decision, and agreed that Arch was liable as Hobet's self insurer on the miner's last day of employment. Arch and Hobet appealed to the Fourth Circuit.
- Facts:
- Arch Coal Company, Inc ("Arch") was the parent company of Hobet Mining, Inc. ("Hobet") and other subsidiaries. Arch insured its own and its subsidiaries' black lung liabilities through a self insurance indemnity bond approved by the Department of Labor. In 2005, Arch sold Hobet to Magnum Coal, which was later transferred Hobet to Patriot Coal Company. The Department of Labor approved Patriot as a self-insurer for Hobet and the two other subsidiaries retroactively to 1973, including the period when Arch owned them.
After Patriot filed for bankruptcy and Hobet ceased operations, the Department of Labor attempted to hold Arch liable for new black lung claims that Patriot could no longer pay. Horace Meredith filed a claim for benefits under the Black Lung Benefits Act ("BLBA") more than 20 years after he last worked at Hobet. The district director, ALJ, and the Benefits Review Board concluded that Hobet was a responsible operator and Arch as Hobet's self insurer at the time of Meredith's last employment was responsible for paying any reward.
- Judge(s):
- KING, AGEE, and QUATTLEBAUM
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