V. Diaz v. Uninsured Employers Guaranty Fund and Bravo Remodeling (WCAB)

CourtCommonwealth Court of Pennsylvania
DecidedAugust 8, 2025
Docket932 C.D. 2023
StatusUnpublished

This text of V. Diaz v. Uninsured Employers Guaranty Fund and Bravo Remodeling (WCAB) (V. Diaz v. Uninsured Employers Guaranty Fund and Bravo Remodeling (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
V. Diaz v. Uninsured Employers Guaranty Fund and Bravo Remodeling (WCAB), (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Vidal Almendarez Diaz, : Petitioner : : v. : No. 932 C.D. 2023 : SUBMITTED: October 8, 2024 Uninsured Employers Guaranty : Fund and Bravo Remodeling : (Workers’ Compensation : Appeal Board), : Respondents :

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY SENIOR JUDGE LEADBETTER FILED: August 8, 2025

Claimant, Vidal Almendarez Diaz, petitions for review from an order of the Workers’ Compensation Appeal Board, which affirmed the decision of a workers’ compensation judge (WCJ) granting the Uninsured Employers Guaranty Fund’s1 motion to dismiss for failure to comply with the statutory notice requirement. After review, we reverse and remand for disposition on the merits. Claimant began working as a laborer for Bravo Remodeling, Employer, in February 2019. On July 28, 2019, Claimant suffered a lower back injury while

1 The Fund was created in 2006 “for the exclusive purpose of paying workers’ compensation benefits due to claimants and their dependents where the employer liable for the payments was not insured [or self-insured] at the time of the work injury.” Pa. Uninsured Emps. Guaranty Fund v. Workers’ Comp. Appeal Bd. (Dudkiewicz), 89 A.3d 330, 332 n.1 (Pa. Cmwlth. 2014). carrying a beam at one of Employer’s work sites. Claimant notified Employer of his work injury that same day. On January 9, 2020, Claimant filed a notice of claim with the Fund pursuant to Section 1603 of the Workers’ Compensation Act (Act).2 Thereafter, in February 2020, Claimant filed a claim petition against the Fund3 describing his work injury as “[l]umbar radiculopathy, left lumbar radiculitis, herniated nucleus pulposus[.]” Certified Record (C.R.) at 9.4 The Fund filed an answer denying all material allegations in the claim petition, including that Claimant timely notified the Fund of his claim. Between May and October 2020, Claimant testified, through an interpreter, at multiple virtual hearings before the WCJ. At a hearing in September 2022, the Fund made an oral motion to dismiss Claimant’s petition, asserting that he did not provide timely notice to the Fund pursuant to Section 1603(b) of the Act, 77 P.S. § 2703(b). Both the Fund and Claimant submitted position statements regarding the motion to dismiss. For his part, Claimant pointed to email correspondence from the Bureau of Workers’ Compensation, Information Services (Bureau) dated December 13, 2019, informing Claimant’s counsel that Employer may not have workers’ compensation insurance. C.R., Item No. 28, Claimant’s Ex. C-7. The WCJ circulated a decision and order on December 2, 2022, granting the Fund’s motion and dismissing Claimant’s petition due to untimely notice. The WCJ determined that under any of three scenarios, as taken from

2 Act of June 2, 1915, P.L. 736, as amended, added by the Act of November 9, 2006, P.L. 1362, 77 P.S. § 2703. 3 Pursuant to Section 1603(d) of the Act, a claim petition against the Fund must be filed “at least 21 days after notice of the claim is made to the [F]und,” but not later than 180 days after notice is given. 77 P.S. § 2703(d). 4 Because the Certified Record was filed electronically and was not paginated, the page numbers referenced herein reflect electronic pagination.

2 Claimant’s own testimony, he failed to provide timely notice to the Fund. Claimant appealed to the Board, which affirmed the WCJ’s decision. This appeal followed. Claimant argues that the WCJ erred by using “a ‘constructive notice’ standard instead of an ‘actual knowledge’ standard” in determining when he knew that Employer was uninsured. Claimant’s Br. at 4. Further, Claimant maintains there is not substantial evidence in the record to support the WCJ’s finding that he failed to provide timely notice of his claim to the Fund.5 We consider these arguments together since they are interrelated. It is axiomatic that the WCJ, as fact finder, “has ‘exclusive authority over questions of credibility and evidentiary weight[,]’” and the WCJ’s findings will not be disturbed on appeal if they are supported by substantial, competent evidence. Borough of Hollidaysburg v. Detweiler (Workers’ Comp. Appeal Bd.), 328 A.3d 569, 580 (Pa. Cmwlth. 2025) [quoting A&J Builders, Inc. v. Workers’ Comp. Appeal Bd. (Verdi), 78 A.3d 1233, 1238 (Pa. Cmwlth. 2013)]. “Substantial evidence is such relevant evidence as a reasonable person might accept as adequate to support a conclusion.” Pa. Uninsured Emps. Guaranty Fund v. Workers’ Comp. Appeal Bd. (Lyle), 91 A.3d 297, (Pa. Cmwlth. 2014). See also A&J Builders, Inc., 78 A.3d at 1238. It is not the function of this Court to reweigh the evidence or to substitute its judgment for that of the WCJ. Cnty. of Allegheny v. Marzano (Workers’ Comp. Appeal Bd.), 329 A.3d 715, 727 (Pa. Cmwlth. 2024); Lyle, 91 A.3d at 303. Our inquiry is limited to “whether there is evidence to support the findings actually made;” whether evidence exists to support alternate findings is irrelevant. A&J Builders, Inc., 78 A.3d at 1238.

5 In the alternative, Claimant argues that if the WCJ did not err in granting the Fund’s motion to dismiss, it nonetheless erred in also dismissing the matter as to Employer. We need not reach this issue given our disposition.

3 Section 1603(b) of the Act provides, in pertinent part, that “[a]n injured worker shall notify the [F]und within 45 days after the worker has been advised by the employer or another source that the employer was uninsured.” 77 P.S. § 2703(b). Section 1603(b)(1) goes on to state: “No employee shall receive compensation from the [F]und unless[] . . . the employee notifies the [F]und within the time period specified in this subsection[.]” 77 P.S. §2703(b)(1). Thus, Section 1603(b) acts as a complete bar to compensation if the Fund has not received timely notice. The question of the timeliness of notice is generally one of fact. See Lyle, 91 A.3d at 304; A&J Builders, Inc., 78 A.3d at 1239. Here, we agree with Claimant that the WCJ’s finding that he failed to provide timely notice of his claim to the Fund is not supported by substantial evidence. The majority of the WCJ’s decision consists of a narrative recounting the witnesses’ testimony and lengthy direct quotes from the parties’ position statements on the timeliness issue. The decision contains only one finding of fact, wherein the WCJ agrees with the Fund that under any of three scenarios—all of which are based on Claimant’s testimony—Claimant failed to provide notice to the Fund within 45 days as required by Section 1603(b) of the Act. First, if we use November 6, 2019 as the operative date, which is when Claimant executed a fee agreement with Counsel, notice to the Fund was not timely because it was provided 65 days later. Second, using the date October 8, 2019, which is purportedly when Counsel began acting on Claimant’s behalf, notice was provided 94 days later and therefore was not timely. Finally, if we use the date when Counsel sought confirmation from the Bureau as to the status of Employer’s workers’ compensation insurance, notice to

4 the Fund was not timely because it was provided 49 days later.6 However, none of the occurrences which correspond with these three dates, in and of themselves, establish that Claimant was advised that Employer was uninsured.

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Related

A & J Builders, Inc. v. Workers' Compensation Appeal Board
78 A.3d 1233 (Commonwealth Court of Pennsylvania, 2013)
Pennsylvania Uninsured Employers Guaranty v. Workers' Compensation Appeal Board
89 A.3d 330 (Commonwealth Court of Pennsylvania, 2014)

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V. Diaz v. Uninsured Employers Guaranty Fund and Bravo Remodeling (WCAB), Counsel Stack Legal Research, https://law.counselstack.com/opinion/v-diaz-v-uninsured-employers-guaranty-fund-and-bravo-remodeling-wcab-pacommwct-2025.