Giant Eagle, Inc. v. Workers' Compensation Appeal Board
39 A.3d 287
| Pa. | 2012Background
- Claimant suffered a work injury on June 4, 1998, while employed by Giant Eagle, Inc.
- Claimant received workers' compensation benefits calculated as $266.87 weekly for partial disability.
- Employer filed a suspension petition under Section 314(a) for Claimant's failure to attend a scheduled medical examination.
- WCJ ordered attendance for December 12, 2007; Claimant agreed but did not attend.
- Employer sought suspension of wage loss benefits; WCJ suspended wage loss benefits effective December 12, 2007, pending medical examination.
- Commonwealth Court and Supreme Court analyzed whether “compensation” in Section 314(a) includes medical benefits as well as wage loss benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Section 314(a) require compensation to include medical benefits as well as wage loss? | Givner: compensation may include medical benefits in proper context. | Giant Eagle: compensation in 314(a) is limited to wage loss benefits once liability is established. | Compensation need not always include medical benefits; discretionary suspension may apply to wage loss or both. |
| Can WCJs suspend only wage loss benefits or both wage loss and medical benefits under 314(a)? | Givner: WCJ may suspend both wage loss and medical benefits when appropriate. | Giant Eagle: interpretation should limit suspension to wage loss benefits only. | WCJs have discretion to deprive the claimant of wage loss benefits or both wage loss and medical benefits under 314(a). |
| Is the term 'compensation' ambiguous in 314(a) requiring purposive statutory construction? | Ambiguity exists; Article III uses 'compensation' variably to include medical benefits in some contexts. | Term generally denotes wage loss; ambiguity resolved against expansive reading. | There is textual ambiguity; but interpretation favorable to claimant is not required; balancing purpose supports discretionary suspension. |
Key Cases Cited
- Berwick Industries v. Workmen's Compensation Appeal Board (Spaid), 537 Pa. 326, 643 A.2d 1066 (1994) (interprets 'compensation' to include medical benefits in some Article III contexts)
- U.S. Steel Corp. v. Workers' Compensation Appeal Board (Luczki), 887 A.2d 817 (Pa.Cmwlth. 2005) (discusses unreasonable contest and UR; differentiation from 314(a) context)
- O'Brien v. Workers' Compensation Appeal Board (Montefiore Hospital), 690 A.2d 1262 (Pa.Cmwlth. 1997) (footnote cited on distinction of 'compensation' scope)
- Schmucker v. Naugle, 426 Pa. 203, 231 A.2d 121 (1967) (statutory philosophy on limitations and repose relevance)
- Hannaberry HVAC v. Workers' Compensation Appeal Board (Snyder, Jr.), 575 Pa. 66, 834 A.2d 524 (2003) (remedial nature of WCA; liberal construction in worker's favor)
- Harper & Collins v. Workmen's Compensation Appeal Board (Brown), 543 Pa. 484, 672 A.2d 1319 (1996) (borderline interpretations construed in injured party's favor)