Little v. Workers' Compensation Appeal Board
2011 Pa. Commw. LEXIS 344
Pa. Commw. Ct.2011Background
- Claimant seeks fatal claim benefits and total disability benefits for Decedent, who died after receiving a termination letter in Jan. 2006.
- Decedent sustained a shoulder injury on Oct. 1, 2005, began light duty, then returned to regular duties by Jan. 19, 2006.
- Employer terminated Decedent’s employment after a Jan. 28, 2006 letter; Decedent died Jan. 30, 2006.
- WCJ found Decedent not in the course of employment at death and awarded only disability benefits up to Jan. 30, 2006; fatal claim petition denied.
- Board upheld the WCJ’s decision; this Court affirmed, holding Decedent’s death was not work-related because it occurred after termination and lacked causal link to employment.
- The case discusses the evolving legal framework for heart-attack claims and the proper consideration of “course of employment” after termination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether abnormal working conditions are required for physical injuries like heart attack under Panyko | Little argues abnormal conditions not required for physical injuries. | Employer/Board contends abnormal conditions framework is applicable or may be considered. | Abnormal conditions not required for purely physical heart-attack injuries. |
| Whether Decedent died in the course of employment or furthering Employer’s business | Death linked to termination and stress from loss of employment. | Death occurred off-premises with no causal link to ongoing work duties. | Death did not arise in the course of employment; benefits denied. |
| Whether the WCJ erred by relying on or not addressing medical testimony | Medical experts could inform causation; testimony ignored. | WCJ appropriately focused on course of employment; medical opinions not dispositive. | Medical testimony not controlling where no work-related causation shown. |
Key Cases Cited
- Krawchuk v. Philadelphia Elec. Co., 497 Pa. 115, 439 A.2d 627 (Pa. 1981) (establishes course-of-employment test for fatal heart attacks; location only a factor)
- Davis v. Workers’ Comp. Appeal Bd. (Swarthmore Boro), 561 Pa. 462, 751 A.2d 168 (Pa. 2000) (psychic injuries require objective evidence and abnormal conditions analysis; distinguishes physical injuries from psychic claims)
- Panyko v. Workers’ Comp. Appeal Bd. (U.S. Airways), 585 Pa. 310, 888 A.2d 724 (Pa. 2005) (physical injury due to a psychic reaction framework; abnormal conditions not required for physical injuries)
- Erie Bolt Corp. v. W.C.A.B. (Elderkin), 777 A.2d 1169 (Pa. Cmwlth. 1998) (stress of being fired; later reversed by per curiam; discusses causal connection in termination-related cases)
- Slaugenhaupt v. U.S. Steel Corp., 31 Pa. Cmwlth. 329, 376 A.2d 271 (Pa. Cmwlth. 1977) (examines course-of-employment concepts on and off premises)