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Eleventh Circuit Clarifies Automatic Entitlement Provision of Black Lung Benefits Act

Yesterday, the Eleventh Circuit resolved an ambiguity regarding when miners’ survivors can recover benefits under the Black Lung Benefits Act.  Pursuant to the Act, survivors can recover in two ways.  First, they can prove that the miner died from a lung disease caused by pneumoconiosis.  Alternatively, they can proceed under the “automatic entitlement” provision (30...