Deference to ALJ Findings in Longshore Act Claims: Substantial Evidence and APA Compliance

Introduction

J. Larry Willis v. Director, Office of Workers’ Compensation Programs, U.S. Department of Labor; Virginia International Terminals, LLC, decided May 28, 2025 by the Fourth Circuit (No. 23-2048), addresses the scope of judicial review under the Longshore and Harbor Workers’ Compensation Act (Longshore Act). Willis injured his back in a May 2018 workplace accident and sought additional disability benefits. An Administrative Law Judge (ALJ) denied his claim, finding his testimony not credible and crediting one medical opinion over another. The Benefits Review Board (BRB) affirmed, and Willis petitioned for review in the Fourth Circuit. The court denied relief, emphasizing (1) the “substantial evidence” standard for fact findings under 33 U.S.C. § 921(b)(3), and (2) the APA explanation requirement, 5 U.S.C. § 557(c)(3)(A).

Summary of the Judgment

The Fourth Circuit, sitting en banc by unpublished per curiam opinion, denied Willis’s petition for review. Key points:

The ALJ found Willis’s trial testimony about no prior back pain incredible, given his undisclosed history of accidents and medical visits dating back to 1996.
The ALJ credited Dr. Goss’s opinion—that Willis’s ongoing pain stemmed from preexisting degenerative changes—over Dr. Wardell’s view that the May 2018 accident caused the injury.
The BRB affirmed, holding that the ALJ’s causation findings were supported by substantial evidence and that the APA required no further explanation.
The Fourth Circuit applied deferential review: fact findings are conclusive if supported by substantial evidence; legal issues and APA compliance are reviewed de novo.

Analysis

Precedents Cited

33 U.S.C. § 921(b)(3): “Findings of fact by the [ALJ] shall be conclusive if supported by substantial evidence.”
Gilchrist v. Newport News Shipbuilding & Dry Dock Co., 135 F.3d 915 (4th Cir. 1998): Affirms the substantial evidence standard for BRB decisions.
Island Creek Coal Co. v. Blankenship, 123 F.4th 684 (4th Cir. 2024): Defines substantial evidence as “relevant evidence that a reasonable mind might accept as adequate.”
Ceres Marine Terminals, Inc. v. Green, 656 F.3d 235 (4th Cir. 2011): Endorses deference to credibility determinations and inferences by the factfinder.
Metro Mach. Corp. v. DOWCP, 846 F.3d 680 (4th Cir. 2017): Discusses de novo review of BRB’s adherence to its standards.
See v. Washington Metro. Area Transit Auth., 36 F.3d 375 (4th Cir. 1994): Details APA’s reasoned decisionmaking requirements.
Moody v. Huntington Ingalls Inc., 879 F.3d 96 (4th Cir. 2018): Confirms Fourth Circuit’s jurisdiction under 33 U.S.C. § 921(c).

Legal Reasoning

The Fourth Circuit’s analysis rests on two pillars:

Substantial Evidence Review
Under 33 U.S.C. § 921(b)(3), the court must uphold ALJ fact findings if a reasonable mind could accept them as adequate. Willis’s extensive back‐pain history—1996 car accident, 2008 workplace incident, 2011 complaint, 2013 MRI showing disc bulge—contradicted his trial testimony denying any prior pain. The ALJ reasonably inferred that nondisclosure to medical providers revealed a desire to strengthen his claim. The Fourth Circuit emphasized that alternative inferences or credibility assessments cannot override substantial evidence.
APA Explanation Requirement
The Administrative Procedure Act mandates that an ALJ “include a discussion of findings and conclusions, and the reasons or basis therefor.” 5 U.S.C. § 557(c)(3)(A). The court held that thorough, coherent explanations of credibility assessments, evidentiary weight, and statutory application suffice. Excessive verbosity is not required; clarity and logical reasoning satisfy the APA.

Impact

This decision reinforces key administrative law principles in the Longshore Act context:

Credibility and Nondisclosure: Factfinders may infer that omission of medical history indicates bias or strategy, strengthening the duty of claimants to disclose fully.
Medical Opinion Weight: Courts will defer to reasoned medical analyses that incorporate comparative imaging and pathophysiology over conclusory causation opinions lacking full background.
Deference to ALJ: The Fourth Circuit reaffirms its reluctance to second‐guess credibility and evidentiary weight decisions, narrowing successful appeals.
APA Compliance: ALJs are reminded to articulate their reasoning succinctly; brief but clear explanations are adequate.

Complex Concepts Simplified

Substantial Evidence: Not the highest possible proof, but enough that a reasonable person would accept it. Think of it as “more than a scintilla” but less than a preponderance.
De Novo vs. Substantial Evidence Review: De novo means the court conducts its own review of legal issues. Substantial evidence means the court broadly defers to the factfinder’s choices unless no reasonable person could agree.
Administrative Procedure Act (APA): Federal law requiring agencies to explain decisions so that parties and reviewing courts can understand the rationale.
BRB and ALJ Roles: The ALJ hears evidence and issues an initial decision. The BRB reviews that decision for legal and procedural correctness. Courts then review the BRB’s decision under standards set by the statute.

Conclusion

Willis v. DOWCP underscores the high bar for overturning ALJ findings under the Longshore Act. The Fourth Circuit’s insistence on substantial evidence and concise APA explanations preserves administrative efficiency and stability in benefit adjudications. Claimants must present fully transparent medical histories and robust causation evidence, while ALJs are encouraged to document reasoning clearly but without needless elaboration. This decision will guide future adjudications and appeals in the maritime and workers’ compensation spheres.