J. Caldwell v. Towanda (WCAB)

CourtCommonwealth Court of Pennsylvania
DecidedMarch 26, 2025
Docket498 C.D. 2024
StatusUnpublished

This text of J. Caldwell v. Towanda (WCAB) (J. Caldwell v. Towanda (WCAB)) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J. Caldwell v. Towanda (WCAB), (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Jared Caldwell, : Petitioner : : No. 498 C.D. 2024 v. : : Argued: March 4, 2025 Towanda (Workers’ Compensation : Appeal Board), : Respondent :

BEFORE: HONORABLE ANNE E. COVEY, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE MATTHEW S. WOLF, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE DUMAS FILED: March 26, 2025

Jared Caldwell (Claimant) has petitioned this Court to review an adjudication of the Workers’ Compensation Appeal Board (Board), which affirmed the decision of the Workers’ Compensation Judge (WCJ) in favor of Towanda (Employer). On appeal, Claimant contends, inter alia, he was not a seasonal employee and that he suffered a right neck injury. We vacate in part, dismiss in part, affirm in part, and reverse in part the Board’s decision, and we remand with instructions. I. BACKGROUND1 Employer runs an overnight summer camp for children, which provides various outdoor activities. Claimant contracted with Employer to be an excursion director for ten weeks starting June 1, 2021. The parties’ contract required Claimant

1 Unless otherwise stated, we state the background based on the WCJ’s and Board’s decisions, which are supported by substantial evidence. See WCJ Op., 5/19/23; Bd. Op., 4/3/24. to supervise and live with a group of campers but did not specify any particular work duties. See generally Ex. C-11 (employment contract).2 Instead, the parties’ contract obligated Claimant to perform “any and all” assigned duties, which “may be modified by” Employer. Id. Claimant and Employer testified about their understanding of Claimant’s work duties as an excursion director. Claimant testified live that his job duties included participating in hikes and overnight trips and using the rock-climbing tower as part of Employer’s outdoor adventure program. On any given day, he would hoist safety equipment, kayaks, and other gear weighing between 10 to 150 pounds up the tower. At other times of the year, Claimant also led mountaineering excursions in Oregon, both in late summer as well as in the winter months. Claimant maintained that he could be an excursion director year-round. Mitchell Reiter, owner and director of Employer, disagreed that Claimant could be an excursion director year-round. N.T. Reiter Dep., 9/30/22, at 15 (answering in the negative to the question of whether an excursion director could work “at any other time other than the summer”). In Reiter’s view, this was a “trick question” because this was a “summer position, summer job. It’s not a year-round job.” Id. Reiter denied employing any full-time, year-round excursion directors. Reiter, however, generally agreed with Claimant’s description of his work duties. Reiter added that other outdoor activities included challenge courses, building campfires, archery, nature hikes, and leading canoe trips. In addition to Claimant’s job-specific duties, Reiter noted that all employees participated in certain common duties, including supervising the children and helping out as needed, e.g., 2 The parties’ contract incorporated by reference a “Staff Guide,” which was not part of the record. Although the contract stated that Claimant’s title was “Excursion Leader,” the parties also interchangeably used the title “Excursion Director.” Notes of Testimony (N.T.) Hr’g, 8/18/22. The parties and record do not distinguish the two titles.

2 at the canteen, doing laundry, playing pickup games, or mowing the lawn. Reiter stated that employees “have a lot of flexibility in their” job. Id. at 10. On June 16, 2021, Claimant was descending the rock-climbing tower when he fell approximately ten feet and injured his right back and right neck, although the parties dispute Claimant’s neck injury. Claimant visited the infirmary that day. However, his symptoms worsened, and he returned home to Colorado. Claimant unsuccessfully requested total disability benefits from Employer. Claimant then filed contested claim and penalty petitions. The parties stipulated that Claimant suffered from right neck pain but that Employer could litigate the description of the work injury. An independent medical examination (IME) and several WCJ hearings ensued, at which Claimant presented the trial deposition of Dr. Stephen Shogan and the IME report by Dr. Jeffrey Sabin, which we detail below. Generally, the IME report found Claimant suffered from right neck radiculitis and right leg radiculopathy. Claimant’s counsel also presented his resume, bills, and four affidavits from other counsel in support of his contention that his $395 hourly rate was reasonable for workers’ compensation matters in northeastern Pennsylvania. The WCJ granted the claim petition and partially granted the penalty petition with an award of counsel fees. The WCJ described Claimant’s work injury as, inter alia, severe right neck pain and right leg radiculopathy.3 The WCJ held that Claimant was a seasonal employee and reduced counsel’s hourly rate from $395 to $200, based on the WCJ’s personal knowledge of the prevailing hourly rates for workers’ compensation matters in northeastern Pennsylvania. The WCJ did not award statutory interest and made no credibility findings despite the parties’

3 The parties do not dispute Claimant’s other work injuries, which included a thoracic sprain/strain.

3 conflicting testimony on when Claimant could be an excursion director. The WCJ did not cite any law or explain its holding that Claimant was a seasonal employee. Both Claimant and Employer appealed to the Board, which issued a mixed decision partially adverse to Claimant. In relevant part, the Board reversed the WCJ’s description of Claimant’s work injury to the extent it included severe right neck pain and right leg radiculopathy. The Board affirmed the WCJ’s reduction of Claimant’s counsel’s hourly rate to $200. The Board modified the WCJ’s decision to include statutory interest on Claimant’s benefits, penalties, and other expenses.4 The Board also affirmed the WCJ’s determination that Claimant was a seasonal employee. The Board reiterated the WCJ’s conclusion that “nowhere in [Claimant’s] employment contract was it stated that Claimant’s job was to be anything more than seasonal employment and [the WCJ] found Claimant to be a seasonal employee.” Bd. Op. at 17. The Board acknowledged that although the WCJ “did not render any express credibility determinations,” the WCJ must have rejected Claimant’s testimony that he could work year-round. Id. (“The logical corollary of [the WCJ’s] conclusion is that Claimant’s opposing testimony, that the position of excursions director was not strictly a summertime position, was not credible.”). Claimant timely appealed to this Court. II. ISSUES5 Claimant raises four issues. First, Claimant asserts that the Board erred by holding that Claimant was a seasonal employee. Claimant’s Br. at 4. Second, notwithstanding the Board’s award of statutory interest, Claimant argues the WCJ 4 Employer challenged, inter alia, the WCJ’s decision granting Claimant’s penalty petition, which the Board affirmed adverse to Employer. Further, as we detail below, notwithstanding the Board’s award of statutory interest, Claimant raises the issue on appeal to this Court. 5 Claimant raises four issues, but the argument portion of his appellate brief is divided into three sections, which violates Pa.R.A.P. 2119(a). See Pa.R.A.P. 2119(a) (mandating that the “argument shall be divided into as many parts as there are questions to be argued”).

4 erred by not awarding such interest. Id. Third, Claimant maintains that the Board should have reversed the WCJ’s reduction of counsel’s hourly rate. Id. Fourth, Claimant asserts that the Board erred by reversing the WCJ’s finding that Claimant suffered a right neck injury. Id. III. DISCUSSION6 A.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Woodard v. Chatterjee
827 A.2d 433 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Crawley
924 A.2d 612 (Supreme Court of Pennsylvania, 2007)
Daniels v. Workers' Compensation Appeal Board
828 A.2d 1043 (Supreme Court of Pennsylvania, 2003)
Leon E. Wintermyer, Inc. v. Workers' Compensation Appeal Board
812 A.2d 478 (Supreme Court of Pennsylvania, 2002)
Signora v. Liberty Travel, Inc.
886 A.2d 284 (Superior Court of Pennsylvania, 2005)
Vitac Corp. v. Workers' Compensation Appeal Board
854 A.2d 481 (Supreme Court of Pennsylvania, 2004)
Ramich v. Worker's Compensation Appeal Board
770 A.2d 318 (Supreme Court of Pennsylvania, 2001)
Burke, A., Aplt. v. Independence Blue Cross
103 A.3d 1267 (Supreme Court of Pennsylvania, 2014)
The Arches Condominium Association v. L. Robinson
131 A.3d 122 (Commonwealth Court of Pennsylvania, 2015)
Froehly v. Harton
139 A. 727 (Supreme Court of Pennsylvania, 1927)
Pusey's Estate
184 A. 844 (Supreme Court of Pennsylvania, 1935)
Patterson's Estate
3 A.2d 320 (Supreme Court of Pennsylvania, 1938)
Tioga Orchards, LLC and Nationwide Ins. Co. v. WCAB (Gaffney)
156 A.3d 407 (Commonwealth Court of Pennsylvania, 2017)
Ross v. Workers' Compensation Appeal Board
702 A.2d 1099 (Commonwealth Court of Pennsylvania, 1997)
Lawson v. Workers' Compensation Appeal Board
857 A.2d 222 (Commonwealth Court of Pennsylvania, 2004)
Braun v. Wal-Mart Stores, Inc.
24 A.3d 875 (Superior Court of Pennsylvania, 2011)
Kapler v. Camp Taghconic, Inc.
215 A.D. 51 (Appellate Division of the Supreme Court of New York, 1926)

Cite This Page — Counsel Stack

Bluebook (online)
J. Caldwell v. Towanda (WCAB), Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-caldwell-v-towanda-wcab-pacommwct-2025.