Steeple v. Workers' Compensation Appeal Board

796 A.2d 394, 2002 Pa. Commw. LEXIS 182
CourtCommonwealth Court of Pennsylvania
DecidedApril 8, 2002
StatusPublished
Cited by6 cases

This text of 796 A.2d 394 (Steeple v. Workers' Compensation Appeal Board) 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
Steeple v. Workers' Compensation Appeal Board, 796 A.2d 394, 2002 Pa. Commw. LEXIS 182 (Pa. Ct. App. 2002).

Opinions

[396]*396OPINION BY

DOYLE, Senior Judge.

John Steeple (Claimant) petitions this Court for review of an order of the Workers’ Compensation Appeal Board (Board), which reversed the order of a Workers’ Compensation Judge (WCJ) ordering the Pennsylvania Liquor Control Board (Employer) to pay Claimant’s counsel fees for its unreasonable contest.

On May 13, 1991, Claimant sustained a work-related injury while working for Employer and received benefits pursuant to a notice of compensation payable. Employer filed a petition to modify on March 22, 1993, asserting that Claimant had failed to return to work although released for light duty with certain restrictions. Claimant filed a timely answer, which denied the allegation of Employer’s petition and requested attorney’s fees for an unreasonable contest. The WCJ denied Employer’s request for supersedeas and approved a counsel fee of twenty percent to be deducted from Claimant’s share of the ongoing benefits.

At a July 13, 1995, hearing, Employer offered the deposition testimony of M. Barry Lipson, M.D., its medical expert, and Joann Cassidy, a vocational witness. Dr. Lipson reviewed seven job descriptions that had been referred to Claimant by Employer. Two of the seven jobs did not fall within the prescribed physical restrictions that Dr. Lipson imposed on Claimant. At the time of Ms. Cassidy’s testimony, Employer only proceeded with respect to three of the seven jobs that were referred to Claimant. After presenting all of its evidence, Employer withdrew its petition on February 22, 1996. The WCJ, however, held the case open for a determination of whether Employer’s contest was reasonable.

The WCJ determined that Employer’s contest was unreasonable and awarded attorney’s fees finding that Employer knew, or should have known, that prosecuting this action was unreasonable before filing its Petition in March of 1993. The Board subsequently reversed the WCJ’s decision and held that when Employer filed its petition “it could have met its initial burden with the testimony of Dr. Lipson that Claimant’s physical condition had changed, and its second burden with [Ms. Cassidy’s testimony] that work within Claimant’s restrictions was offered to him.” (Board Opinion at 5). The Board held that the WCJ erred in determining that Employer knew or should have known that its case was not reasonable. Accordingly, the Board held that Claimant was not entitled to attorney’s fees. Claimant now appeals to this Court.

The sole issue that is before us is whether Employer established the reasonableness of its contest so as to avoid liability for attorney’s fees. Whether an employer’s contest is reasonable is a question of law fully reviewable by this Court, Boyer v. Workers’ Compensation Appeal Board (First Capital Insulation, Inc.), 740 A.2d 294 (Pa.Cmwlth.1999), and, of course, our standard of review is limited to determining whether constitutional rights were violated, whether an error of law was committed or whether necessary findings of fact are supported by substantial evidence. Section 704 of the Administrative Agency Law, 2 Pa.C.S. § 704; Morey v. Workmen’s Compensation Appeal Board (Bethenergy Mines, Inc.), 684 A.2d 673 (Pa.Cmwlth.1996).

As recognized by the Board, the well-settled law that governs this case was set forth in Kachinski v. Workmen’s Compen[397]*397sation Appeal Board (Vepco Construction Co.), 516 Pa. 240, 532 A.2d 374 (1987), by our Supreme Court. In Kachinski, the Court explained the appropriate procedure that should be followed when an employer seeks to modify a claimant’s benefits:

1. The employer who seeks to modify a claimant’s benefits on the basis that he has recovered some or all of his ability must first produce medical evidence of a change in condition.
2. The employer must then produce evidence of a referral (or referrals) to a then open job (or jobs), which fits in the occupational category for which the claimant has been given medical clearance, e.g., fight work, sedentary work, etc.
3. The claimant must then demonstrate that he has in good faith followed through on the job referral(s).
4. If the referral fails to result in a job then claimant’s benefits should continue.

Id. at 252, 532 A.2d at 380.

Ordinarily, pursuant to Section 440 of the Workers’ Compensation Act (Act),2 77 P.S. § 996, a prevailing claimant is entitled to attorney’s fees unless the record supports a conclusion that the employer had a reasonable basis for contesting liability; and, the employer bears the burden of presenting sufficient evidence to establish that its contest was reasonable. Pruitt v. Workers’ Compensation Appeal Board (Lighthouse Rehabilitation), 730 A.2d 1025 (Pa.Cmwlth.1999). Generally, a reasonable contest is one that is prompted by a genuinely disputed issue and not merely done to harass a claimant. Harney v. Workmen’s Compensation Appeal Board (Philadelphia Coca Cola Bottling Co.), 660 A.2d 665 (Pa.Cmwlth.1995). The purpose of Section 440 of the Act is to discourage unreasonable contests of workers’ claims and to ensure that successful claimants receive compensation benefits that are undiminished by the costs of litigation. Wertz v. Workmen’s Compensation Appeal Board (Department of Corrections), 683 A.2d 1287 (Pa.Cmwlth.1996), petition for allowance of appeal denied, 547 Pa. 747, 690 A.2d 1165 (1997).

Claimant, in his brief to this Court, acknowledges that Employer presented sufficient evidence to meet the first two requirements of Kachinski;3, therefore, pursuant to Kachinski, Claimant would have then had the burden to prove that he had in good faith followed through on the job referrals. However, Claimant contends that, because Employer withdrew its case after it met the first two elements of Kachinski, Claimant was, therefore, deprived of proving he had applied for the offered jobs in good faith. Accordingly, Claimant argues, Employer must necessarily have known that its case had no merit at the time it was filed. We must disagree with Claimant’s analysis.

Contrary to Claimant’s argument, this Court has explained that merely considering whether the petition has been withdrawn or dismissed is not enough to determine if the petition was reasonable; rather, the totality of the circumstances must be considered. Eidell v. Workmen’s Compensation Appeal Board (Dana Corp.), 155 Pa.Cmwlth. 254, 624 A.2d 824 (1993). See also Majesky v. Workmen’s Compensation Appeal Board (Transit America, Inc.), 141 Pa.Cmwlth. 398, 595 A.2d 761

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

Related

L. Sarmiento-Hernandez v. WCAB (Ace American Insurance Company)
179 A.3d 105 (Commonwealth Court of Pennsylvania, 2018)
M. Mohamed v. WCAB (Lincoln Recycling)
Commonwealth Court of Pennsylvania, 2015
City of Philadelphia v. Workers' Compensation Appeal Board
948 A.2d 221 (Commonwealth Court of Pennsylvania, 2008)
Frankford Hospital v. Workers' Compensation Appeal Board
906 A.2d 651 (Commonwealth Court of Pennsylvania, 2006)
Budd Co. v. Workers' Compensation Appeal Board
858 A.2d 170 (Commonwealth Court of Pennsylvania, 2004)
Steeple v. Workers' Compensation Appeal Board
796 A.2d 394 (Commonwealth Court of Pennsylvania, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
796 A.2d 394, 2002 Pa. Commw. LEXIS 182, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steeple-v-workers-compensation-appeal-board-pacommwct-2002.