US Airways, Aplts. v. WCAB (Bockelman)

CourtSupreme Court of Pennsylvania
DecidedNovember 20, 2019
Docket35 WAP 2018
StatusPublished

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

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US Airways, Aplts. v. WCAB (Bockelman), (Pa. 2019).

Opinion

[J-22-2019] IN THE SUPREME COURT OF PENNSYLVANIA WESTERN DISTRICT

SAYLOR, C.J., BAER, TODD, DONOHUE, DOUGHERTY, WECHT, MUNDY, JJ.

US AIRWAYS, INC. AND SEDGWICK : No. 35 WAP 2018 CLAIMS MANAGEMENT SERVICES, : INC., : Appeal from the Order of the : Commonwealth Court entered Appellants : February 22, 2018 at No. 612 CD : 2017, affirming the Order of the : Workers’ Compensation Appeal Board v. : dated April 19, 2017 at No. A16-0545. : : ARGUED: May 14, 2019 WORKERS’ COMPENSATION APPEAL : BOARD (BOCKELMAN), : : Appellees :

Justice Wecht delivers the Opinion of the Court with respect to Parts I, II and IV and announces the Judgment of the Court. Justice Wecht also delivers an opinion as to Part III.

OPINION

JUSTICE WECHT DECIDED: NOVEMBER 20, 2019 This appeal involves an airline employee who was injured while riding an airport

shuttle bus to an employee parking lot after her shift ended. The question before us is

whether the employee’s injury can be said to have occurred on the airline’s premises for

purposes of the Workers’ Compensation Act even though the City of Philadelphia owned

both the shuttle bus and the employee parking lot.

I. The Claimant in this appeal, Betty Bockelman, is a Philadelphia-based flight

attendant. On January 23, 2015, Bockelman was scheduled to work a one-day trip from

Philadelphia to Miami and then back to Philadelphia. On that morning, Bockelman drove

her personal vehicle to the Philadelphia International Airport and parked (for free) in one

of two employee parking lots at the airport. Bockelman’s employer, US Airways,1 does

not own or operate these parking lots. Instead, the City of Philadelphia Division of

Aviation (“the Division” or “Division of Aviation”) owns, operates, and maintains the

parking lots specifically for airport and airline employees.

Anyone seeking to enter the Division’s restricted parking lots must swipe a special

credential called a Secured Identification Display Area (“SIDA”) badge. The Division is

responsible for issuing SIDA badges to all airport employees with jobs that require access

to secure areas of the airport. The Division conducts a background check and

fingerprinting before issuing a SIDA badge to an airline employee. When a new employee

is hired, her employer pays the Division of Aviation a one-time administrative fee to cover

the cost of the badge and the background check.

After an employee parks in one of the reserved lots, a Division of Aviation shuttle

bus transports the employee to the airport terminal.2 These shuttles are not open to the

public; they are for airport employees only. US Airways itself does not own or exercise

control over the shuttle buses, nor does it pay the Division any fees for its employees to

use the shuttles. US Airways does not require employees to use the Division’s parking

1 Not long after Bockelman’s injury, US Airways and American Airlines completed a merger and formed American Airlines Group, Inc. To avoid confusion, however, we will continue to refer to Bockelman’s employer as “US Airways.” 2 Although the City of Philadelphia owns these shuttle buses, a private company called First Transit manages day-to-day operations of the shuttle service.

[J-22-2019] - 2 lots or shuttle service. In fact, US Airways gives its employees no guidance at all

regarding how they should commute to work.

On the day of her injury, Bockelman rode the Division shuttle to the airport terminal

and flew to Miami as scheduled. She then returned back in Philadelphia just before 10:00

p.m. that evening. After a brief discussion with a co-worker, Bockelman left the terminal

and boarded the shuttle bus to take her back to her vehicle. While lifting her suitcase

onto one of the shuttle’s luggage racks, Bockelman slipped in a puddle, fell backwards,

and crushed her left foot.

Bockelman later filed a workers’ compensation claim petition alleging that she

sustained disabling foot and ankle injuries as a result of the January 2015 slip and fall.

She sought total temporary disability benefits for a closed period from January 23, 2015

(the date of her injury) through April 19, 2015 (when she ultimately returned to work). US

Airways filed an answer, denying that Bockelman was within the course of her

employment at the time of her injury. See 77 P.S. § 411(1) (defining a compensable injury

to mean an injury that arises in the course of employment).

A Workers’ Compensation Judge (“WCJ”) held a hearing on Bockelman’s claim

petition in late October 2015. In support of her petition, Bockelman testified that, at the

time of her injury, she was a member of the Association of Flight Attendants (“AFA”), a

labor union representing flight attendants. Bockelman also produced a collective

bargaining agreement between the AFA and US Airways, which included a provision

stating that US Airways was responsible for providing either free or reimbursed parking

for flight attendants at their domicile airports.

In opposition, US Airways presented documentary evidence and offered the

testimony of Anthony Stanley, the Director of Planning and Administration for US Airways.

Stanley testified that US Airways did not pay for Bockelman, or any other Philadelphia-

[J-22-2019] - 3 based flight attendants, to park in the employee parking lots at the Philadelphia

International Airport. Stanley explained that the City of Philadelphia owns and operates

all airport-employee parking lots, including the lot in which Bockelman parked on the day

that she was injured. Stanley testified that the Division’s lots are not only for US Airways’

employees; rather, they are open to all airport and airline employees. Finally, while

Stanley acknowledged that the AFA’s collective bargaining agreement states that US

Airways will provide free or reimbursed parking for flight attendants, he testified that those

specific provisions do not apply to flight attendants like Bockelman who are domiciled in

Philadelphia, since the Division of Aviation already provides free parking for airport

employees.

The WCJ granted Bockelman’s claim petition. In his decision, the WCJ explained

that, if an employee is not actively furthering her employer’s business or affairs when she

suffers an injury, the injury arises in the course of employment only if: (1) the injury occurs

on the employer’s premises; (2) the employee’s presence on the employer’s premises is

required by the nature of her employment; and (3) the employee’s injury was caused by

the condition of the premises or by the operation of the employer’s business thereon.3

WCJ Opinion, 4/27/2016, at 11; see 77 P.S. § 411(1).

The WCJ found that Bockelman’s injury satisfied all three elements of this test. As

for the first prong, the WCJ noted that Bockelman was injured while “taking a specifically

designated shuttle bus to an employee parking lot that required an identification card (the

SIDA badge) for entry and exit.” WCJ Opinion, 4/27/2016, at 11. Turning to the second

prong, the WCJ stressed that Bockelman “boarded the [shuttle] bus soon after her flight

had landed in Philadelphia.” Id. Finally, with regard to the third prong, the WCJ noted

3 Courts sometimes refer to this three-factor inquiry as the Slaugenhaupt test, though the elements derive from Section 301(c)(1) of the Act directly. 77 P.S. § 411(1); see generally W.C.A.B. (Slaugenhaupt) v. U.S.

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