Caputo v. Workers' Compensation Appeal Board
2012 Pa. Commw. LEXIS 9
| Pa. Commw. Ct. | 2012Background
- Caputo petitions for review of a WCAB ruling denying her offset review petition.
- In 2002 Caputo sustained a work injury; awarded total disability benefits of $452.85/week.
- In 2006 Caputo began receiving Social Security retirement benefits ($862/month) and a State Employees Retirement System pension ($405.47/month).
- Employer offset disability benefits by 50% of Social Security retirement benefits ($99.31/week) and $74.56/week for SERS; benefits suspended to recoup overpayment.
- WCJ approved the offset and amount; Board affirmed without addressing the constitutional issue; Caputo challenges the Social Security offset as unconstitutional under Pa. Const. Art. I, §1.
- The court analyzes whether Section 204(a) creates a constitutionally permissible classification under rational-basis review and ultimately sustains the offset as reasonably related to legitimate governmental interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Section 204(a) offset for Social Security benefits violate equal protection? | Caputo asserts a constitutional violation. | Employer argues rational-basis review sustains the offset. | No; offset passes rational-basis review. |
| Should Merrill v. Utah Labor Comm. control Pennsylvania analysis? | Caputo urges Merrill as controlling. | Kramer controls; Merrill inapplicable. | Merrill not adopted; rational-basis standard applied. |
| Is Section 204(a) a permissible legislative classification promoting legitimate interests? | Classification unjustified; benefits not duplicative. | Offset reduces employer costs and promotes workforce participation. | Yes; reasonably related to cost containment and encouraging work. |
| Is the 50% offset consistent with exceptions for pre-injury SS receipt and post-retirement work policy? | Exception undermines equal protection. | Exception aligns with post-retirement workforce goals. | Yes; exception supports statutory goals and rational basis. |
Key Cases Cited
- Kramer v. Workers' Compensation Appeal Board (Rite Aid Corp.), 584 Pa. 309 (2005) (equal-protection analysis of offset for severance benefits applies to Social Security offset)
- McCusker v. Workmen's Compensation Appeal Board (Rushton Mining Co.), 536 Pa. 380 (1994) (rational-basis review for social-welfare benefits classifications)
- Merrill v. Utah Labor Comm'n, 223 P.3d 1089 (Utah 2009) ( Utah offset invalid under Utah Constitution; not controlling here)
- Curtis v. Kline, 542 Pa. 249 666 A.2d 265 (1995) (classification legitimacy under equal protection standard)
- Bowen v. Gilliard, 483 U.S. 587 (1987) (rational-basis scrutiny in welfare-benefits contexts)
- Dandridge v. Williams, 404 U.S. 78 (1971) (rational-basis review framework for classifications)