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Arch Coal, Inc. v. Acosta

ELR Citation: 48 ELR 20070
Nos. 17-5074, (D.C. Cir., 04/27/2018)

The D.C. Circuit held that a mining company must exhaust its administrative remedies before it can challenge potential claims filed against it under the Black Lung Benefits Act (BLBA). The BLBA grants coal miners the right to monthly benefits payments from a former employer in the event they suffer from black lung disease as a result of employment. Under the Act, the Department of Labor issues a "bulletin" directing staff to send notice of claims to coal mine operators who are potentially liable for benefits payments under the Act. After receiving such notice, the company alleged that it was not liable for the payments and that the bulletin was a legislative rule issued in violation of the APA. But the BLBA's comprehensive scheme of administrative review, followed by judicial review in a court of appeals, makes it clear that Congress implicitly precluded district court jurisdiction over the claims to which the BLBA applies. The company must therefore exhaust its administrative remedies and secure a final order from the Benefits Board before it may seek review.