L. Campbell v. WCAB (City of Philadelphia), L. Campbell v. WCAB (City of Philadelphia)

Claimant Lawrence Campbell, a former Philadelphia firefighter (1968–2003), filed a workers’ compensation Claim Petition on August 6, 2012 alleging occupational prostate cancer and seeking wage loss and medical benefits.
Claimant also filed a Penalty Petition alleging employer violated pre-hearing exchange rules.
WCJ hearings occurred from 2012–2014; WCJ denied both petitions, finding untimely injury notice, failure to prove causation, and no penalty violation.
The Board affirmed in part: it held notice was timely but upheld denial because Claimant failed to prove his cancer was causally related to firefighting (WCJ found employer experts more credible).
Central statutory provisions: Section 301(c)(2) (300‑week manifestation rule for occupational disease), Section 108(r) (firefighter cancer definition), and Section 301(f) (special 600‑week filing window for firefighter cancer but presumption applies only if claim is filed within first 300 weeks).
Claimant argued the Board misinterpreted Section 301(f) by requiring filing within 300 weeks to obtain the rebuttable presumption and that the discovery rule should toll the period; the court rejected these arguments and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Section 301(f) allows a firefighter to obtain the statutory presumption if diagnosed within 300 weeks but files claim after 300 weeks (but within 600 weeks)	Campbell: reading Sections 301(c)(2) and 301(f) together extends the 300‑week manifestation period to 600 weeks for firefighters, so he is entitled to the presumption despite filing after 300 weeks	Employer/Board: Section 301(f) is two‑tiered — claim must be filed within 300 weeks to get the presumption; filing after 300 but within 600 weeks preserves the right to sue but not the presumption	Held: Filing date controls; because Campbell filed after 300 weeks he lost the statutory presumption and thus bore burden to prove causation, which he failed to meet
Whether the discovery rule tolls the 300‑week filing requirement in Section 301(f)	Campbell: the discovery rule should extend the time to file because diagnosis and discoverability can lag exposure	Employer/Board: prior Commonwealth Court precedent rejects applying the discovery rule to the 301(f) filing periods	Held: Discovery rule does not extend Section 301(f) filing periods; existing precedents control and tolling is not available

Amandeo v. Workers’ Comp. Appeal Bd. (Conagra Foods), 37 A.3d 72 (Pa. Cmwlth.) (burden to prove injury arose in course of employment and causation)
Sladek v. Workers’ Comp. Appeal Bd., 144 A.3d 1011 (Pa. Cmwlth.) (interpreting Section 301(f) prerequisites and types of cancer caused by workplace exposure)
Hutz v. Workers’ Comp. Appeal Bd. (City of Phila.), 147 A.3d 35 (Pa. Cmwlth.) (discussing presumption and its prerequisites for firefighters)
Fargo v. Workers’ Comp. Appeal Bd. (City of Phila.), 148 A.3d 514 (Pa. Cmwlth.) (two‑tiered limitations under Section 301(f): presumption available only if claim filed within 300 weeks; claims after 600 weeks barred)
Demchenko v. Workers’ Comp. Appeal Bd. (City of Phila.), 149 A.3d 406 (Pa. Cmwlth.) (reaffirming limits on presumption and rejecting discovery‑rule extension)
Capaldi v. Workers’ Comp. Appeal Bd. (City of Phila.), 152 A.3d 1107 (Pa. Cmwlth.) (applying the same Section 301(f) filing‑date rule for firefighter cancer claims)