Moore v. Harris

Charles Moore (plaintiff) was a coal miner who had worked in mines for over 16 years. He worked seven years as an employee and nine years in a family mine. Moore applied for benefits under the Black Lung Benefits Act of 1969. US Secretary of Health and Human Services Patricia Harris (the secretary) (defendant) denied Moore’s claim because he worked for fewer than 10 years as an employee in a mine. The language of the act provides benefits for “any individual who is or was employed in a coal mine.” In 1970, the secretary had promulgated a regulation interpreting the act to cover an “individual who is working or has worked as an employee,” which cut off eligibility for benefits for self-employed miners. Congress updated and reenacted the Black Lung Benefits Act in 1972, adding two presumptions: (1) a 10-year presumption that black lung arose out of employment if the miner was employed in a mine for over 10 years and (2) a 15-year presumption that the miner is totally disabled due to black lung if the miner was employed in a mine for over 15 years. These additions made proving eligibility easier because Congress wanted more miners to receive benefits. In 1978, Congress amended the definition of “miner” to unmistakably include self-employed miners. The legislative history includes no distinction between employee miners and self-employed miners. Members of Congress used the phrases “was employed in a mine” and “worked in a mine” interchangeably. A Senate committee report, which was accepted by the full Senate and House, favored the phrase “worked in.” The legislative history shows no debate, controversy, or even interest in the distinction between employee miners and self-employed miners. When Moore applied for benefits, the administrative law judge (ALJ) applied the secretary’s more restrictive definition of miner and refused to afford Moore the benefit of the statutory presumptions. Moore appealed to the district court, which affirmed the ALJ’s decision. Moore appealed to the United States Court of Appeals for the Fourth Circuit.