M. Tymes v. City of Philadelphia (WCAB)

CourtCommonwealth Court of Pennsylvania
DecidedJanuary 29, 2025
Docket464 C.D. 2024
StatusUnpublished

This text of M. Tymes v. City of Philadelphia (WCAB) (M. Tymes v. City of Philadelphia (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
M. Tymes v. City of Philadelphia (WCAB), (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Mark Tymes, : Petitioner : : v. : No. 464 C.D. 2024 : City of Philadelphia (Workers’ : Compensation Appeal Board), : Respondent : Submitted: December 9, 2024

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE MATTHEW S. WOLF, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE WOLF FILED: January 29, 2025

Mark Tymes (Claimant) petitions this Court for review of the April 5, 2024 order of the Workers’ Compensation Appeal Board (Board) affirming the decision of a workers’ compensation judge (WCJ) that denied Claimant’s petitions for reinstatement of workers’ compensation benefits (Reinstatement Petition) and for penalties (Penalty Petition) (collectively, Petitions) against the City of Philadelphia (Employer). Claimant maintains that Employer’s continued payment of Claimant’s regular salary while he was out of work constituted an acceptance of liability for Claimant’s injury and that Employer violated the Workers’ Compensation Act (Act)1 by ceasing that payment and by failing to issue a timely Notice of Compensation Denial (NCD). Finding no merit to Claimant’s challenges, we affirm the Board.

1 Act of June 2, 1915, P.L. 736, as amended, 77 P.S. §§ 1–1041.1; 2501–2710. I. Background Claimant was working for Employer as a police officer when, in October 2020, he became ill and was diagnosed with COVID-19. Certified Record (C.R.), Item No. 7, WCJ Decision, Finding of Fact (F.F.) No. 1(b.). After a one-week absence from work, Claimant returned on October 13, 2020, but was hospitalized on the same day with lightheadedness. Id., F.F. No. 1(c.). Claimant has not worked since that day. Id., F.F. No. 1(d.). However, Claimant continued to receive regular paychecks and accrue sick and vacation time until March 5, 2022. Id., F.F. No. 1(f.). Employer issued an Notice of Compensation Denial (NCD) on July 20, 2022, in which it indicated an injury date of October 13, 2020, but asserted that Claimant did not suffer a work-related injury. See C.R., Item No. 24. On August 16, 2022, Claimant filed the Petitions alleging that Employer “unilaterally terminated benefits” after accepting liability for a work-related injury by continuing to pay his regular salary, which Claimant referred to as “payment of wages in lieu of benefits.”2 C.R., Item Nos. 3-4. In support of the Petitions, Claimant testified at a January 23, 2023 deposition and at a February 23, 2023 videoconference hearing before WCJ Holly San Angelo. In its defense, Employer offered the August 15, 2022 deposition testimony of Barry Scott, its Deputy Finance Director for Risk Management and its Risk Manager, and the August 25, 2022 deposition testimony of Lieutenant Donald Lowenthal, Infection Control Officer of the Philadelphia Police Department (PPD).

2 Payments in lieu of compensation are “any voluntary or informal compensation, apart from the Act, paid with the intent to compensate for a work-related injury.” Kelly v. Workmen’s Comp. Appeal Bd. (DePalma Roofing), 669 A.2d 1023, 1026 (Pa. Cmwlth. 1995).

2 A. Claimant’s Evidence At his deposition, Claimant stated that he was 52 years old and a 33-year veteran of the PPD. C.R., Item No. 15, Claimant Dep. at 5-6. Sometime before October 2020, Claimant had been assigned to the PPD’s airport unit, where he patrolled the airport’s terminals, roads, and parking garages. Id. at 6. After the onset of the COVID-19 pandemic, Claimant was regularly brought into contact with members of the public and fellow officers who did not wear face masks. Id. Claimant fell ill on October 5, 2020, and received sick pay while absent from work from that date until October 12, 2020. Id. at 8. Claimant returned on the morning of October 13, 2020, but, while putting on his uniform in the station locker room, began to feel “really, really lightheaded.” Id. at 9. Medics transported Claimant to the Hospital of the University of Pennsylvania, where, to Claimant’s recollection, he was diagnosed with COVID-19. Id. at 12. From the hospital, Claimant notified his supervisor of his belief that he was infected with COVID-19 in the locker room. Id. at 10. Claimant recalled that he was under quarantine while hospitalized from October 13, 2020, until October 17, 2020, and, following a brief return home, was kept in the hospital’s intensive care unit (ICU) until October 28, 2020. Id. at 14-15. In the ICU, Claimant recalled, he was “on oxygen around the clock” due to his breathing difficulties. Id. at 15. At the time of his deposition testimony, Claimant continued to receive treatment from his primary care physician and a pulmonologist. Id. at 12. Claimant had not returned to work at the time of his deposition testimony due to the persistence of certain symptoms, which he described as “shortness of breath and a brain fog.” Id. at 11. On cross-examination, Claimant acknowledged that he did not recall responding to any calls at work involving COVID-19 medical emergencies, nor

3 could he recall any unit colleagues testing positive for COVID-19 in the two weeks before his illness. Id. at 22-23. Claimant also acknowledged never filling out an injury or accident report following his hospitalization, despite being aware that Employer requires such a report in cases of work injury or illness. Id. at 32-33. At the February 23, 2023 videoconference hearing, Claimant testified that he continued to experience the complained-of symptoms and had thus not returned to work. C.R., Item No. 13, Hr’g Tr. at 14. Claimant also acknowledged that he continued to receive his regular pay between October 2020 and March 2022, and that Employer’s term for that type of payment was “e-time.” Id. at 16. However, Claimant testified that he did not understand the rationale behind Employer’s payment of e-time; the “only thing [he] knew,” he explained, was that “every two weeks [he] was getting paid.” Id. at 17. In March 2022, a PPD lieutenant informed Claimant that he would need to bring an updated sick note to PPD headquarters in order to remain off work. Id. at 18. When Claimant produced the requested sick note, he was told that he would need to begin using his accrued sick pay if he remained out of work. Id. at 18-19. Claimant acknowledged that, following his transition from e-time pay to sick pay, he did not fill out an injury report or a request for injured-on-duty (IOD) benefits. Id. at 21. At the time of his hearing testimony, Claimant was still receiving his regular sick pay via direct deposit. Id. at 20. B. Employer’s Evidence At his deposition, Mr. Scott testified that he has served as Employer’s Deputy Finance Director in its Risk Management Department and as Employer’s Risk Manager since 2003. C.R., Item No. 20, Scott Dep. at 6. Mr. Scott explained that Risk Management administers several different types of disability benefits for PPD

4 officers, including workers’ compensation, Heart and Lung benefits,3 and benefits pursuant to the COVID-19 Enforcement Officer Disability Benefits Act.4 Id. at 7. When PPD officers believe that they have sustained a work injury, Mr. Scott explained, they are instructed to fill out a City of Philadelphia Accident, Injury & Illness Report, commonly referred to as a COPA II. Id. at 7-8. Mr. Scott explained that the report is necessary so that the relevant management officials may conduct an investigation. Id. at 8. The claim is also forwarded to PMA Management Corporation, Employer’s third-party claims administrator, which performs its own investigation. Id. Following the investigations, the employee is to receive a notification letter explaining the acceptance or denial of the claim, and the benefit that he or she is to receive. Id. Mr.

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

Related

NUS Corp. v. Workmen's Compensation Appeal Board
547 A.2d 806 (Commonwealth Court of Pennsylvania, 1988)
Findlay Township v. Workers' Compensation Appeal Board
996 A.2d 1111 (Commonwealth Court of Pennsylvania, 2010)
Esssroc Materials v. Workers' Compensation Appeal Board
741 A.2d 820 (Commonwealth Court of Pennsylvania, 1999)
Westinghouse Electric Corp. v. Workers' Compensation Appeal Board
823 A.2d 209 (Commonwealth Court of Pennsylvania, 2003)
Bufford v. Workers' Compensation Appeal Board
2 A.3d 548 (Supreme Court of Pennsylvania, 2010)
Lindemuth v. Workers' Compensation Appeal Board
134 A.3d 111 (Commonwealth Court of Pennsylvania, 2016)
Jeannette District Memorial Hospital v. Workmen's Compensation Appeal Board
668 A.2d 249 (Commonwealth Court of Pennsylvania, 1995)
Kelly v. Workmen's Compensation Appeal Board
669 A.2d 1023 (Commonwealth Court of Pennsylvania, 1995)
Mosgo v. Workmen's Compensation Appeal Board
480 A.2d 1285 (Commonwealth Court of Pennsylvania, 1984)

Cite This Page — Counsel Stack

Bluebook (online)
M. Tymes v. City of Philadelphia (WCAB), Counsel Stack Legal Research, https://law.counselstack.com/opinion/m-tymes-v-city-of-philadelphia-wcab-pacommwct-2025.