Worker Wins Appeal in their Pennsylvania Workers’ Compensation Case
On September 25th, 2017, the Commonwealth Court of Pennsylvania ruled in favor of an injured employee in a complex workers’ compensation appeal. The case, Shawn Fields v. Workers’ Compensation Appeal Board, came down to whether or not the worker (Mr. Fields) was actually injured while on the job.
Under Pennsylvania law, an injured person can only recover workers’ compensation benefits if their accident occurred within the “course and scope” of their employment. Here, our top-rated Philadelphia workers’ compensation lawyers discuss this case and explain what injured Pennsylvania workers need to know about the course and scope of employment standard.
Case Background: The Facts
Shawn Fields was employed at Carl G’s Cleanouts, a junk and trash removal company that was operating in the greater Philadelphia metropolitan area. While employed at this business, Mr. Fields had several job responsibilities, including performing basic demolition work where he would be assigned to tear the floors, walls and ceilings out of commercial and residential buildings that were being renovated or removed.
Due to the nature of the work, all of the jobsites were inherently temporary. During the day in question in this case, Mr. Fields had finished his last day working at a jobsite where he had been stationed for the previous two to three weeks.
At the end of his shift, Mr. Fields agreed to accept a ride home from one of his co-workers. At the time, his co-worker was driving a company truck. The plan was to gather up some of the scrap that was remaining at the job site, load it into the truck, then drop it off at the junkyard, after which Mr. Fields would be dropped off at his house. Finally, the co-worker was then planning on returning the company truck to pick up his own vehicle. This was not an uncommon arrangement. Indeed, employees at this company did similar things on a regular basis. Sadly, during this ride, the truck was involved in a serious motor vehicle accident. Mr. Fields went on to file a Pennsylvania workers’ compensation claim for his injuries.
The Workers’ Compensation Claim Was Denied
According to the insurance company that handled the claim, Mr. Fields was not eligible for workers’ compensation benefits. Unfortunately, this is not an unusual occurrence. For injured workers, dealing with insurance companies can be stressful, frustrating and confusing. Insurers are notorious for denying and underpaying valid workers’ compensation claims.
In this case, the insurance company argued that Mr. Fields was not actually hurt on the job at all. Instead, he was hurt while travelling on his own time. Therefore he could not qualify for workers’ compensation benefits. In legal terms, the insurance company was arguing that the injury did not occur within the ‘course and scope’ of his employment, as is required by the Pennsylvania Workers’ Compensation Act.
Understanding the Course and Scope Standard
On the surface level, course and scope questions are relatively straightforward: If you were injured while you were “at work”, then you are eligible to seek workers’ compensation benefits, if you were hurt on your own time, you cannot file a workers’ compensation claim. Of course, in the real world, determining when exactly someone is “on the job” can turn into a very complex question.
In the modern economy, this is becoming an ever more important issue, because an increasing percentage of people are working away from fixed jobsites. Additionally, when workers are required to travel to different jobsites, course and scope questions often must be resolved.
Travel-Related Injuries and Workers’ Compensation
Under Pennsylvania law, injuries that a person sustains when travelling to and from their place of work are typically considered to be outside of the course and scope of their employment. In other words, this means that these injuries are not eligible for workers’ compensation benefits. However, there are some key exceptions to this general rule. More specifically, the following is a list of the four key travel-related exceptions included within Pennsylvania’s workers’ compensation regulations:
- The injured employee works on a contract that includes transportation to and from their place of employment;
- The injured employee has no actual set place of work;
- The injured worker was on a work-related task for their employer at the time of that their accident took place; and
- There are special circumstances present, which indicate that the injured worker was furthering the business interests of their employer at the time the accident occurred.
For injured Pennsylvania workers, these exceptions are very important. If you were injured while travelling for your employer, you might still be eligible for workers’ compensation benefits. If the insurance company denies your claim, please do not give up. You owe it to yourself and your family to have your case reviewed by a qualified Philadelphia workers’ compensation attorney.
Why the Appeals Court Ruled in Favor of the Injured Worker
In the case of Shawn Fields, the insurance company played hardball. Though he had helped drop off scrap metal collected from the jobsite at the junkyard immediately prior to the auto accident, the insurer argued that he was not within the course and scope of his employment when that crash occurred. When a Workers’ Compensation Judge (WCJ) reviewed the case, that judge agreed with the insurance company’s argument, stating that Mr. Fields had failed to meet his burden of proving all of the required elements of his claim.
However, on appeal, the Commonwealth Court of Pennsylvania determined that Mr. Fields was actually injured within the course and scope of his employment. Specifically, the Commonwealth Court focused on the fourth travel-related exception, noting that Mr. Fields was furthering the business interests of his employer at the time that his injured occurred.
The court focused on the fact that Mr. Fields and his co-worker had taken scrap metal off of the jobsite. This is important because that scrap would have had to be removed by someone as part of the contract his employer signed, thus it was in the employer’s business interests to have that metal removed by the company’s workers. As such, Mr. Fields was not injured while on purely personal time, commuting to a place of his choosing, but instead was injured while travelling as a part of his job-related duties for the benefit of his employer. On those grounds, the Commonwealth Court reversed the decision and remanded it to the state’s Workers’ Compensation Appeal Board.
Contact Our Philadelphia Workers’ Compensation Lawyers Today
At Krasno, Krasno & Onwudinjo, our dedicated workers’ compensation lawyers have helped many injured Pennsylvania workers recover the full and fair benefits they deserve. If your workers’ compensation claim was denied because the insurance company believes that your accident occurred outside of the course and scope of your employment, or if your claim was denied for any other reason, we are here to help.
For immediate assistance, please do not hesitate to call us today at 800-952-9640 or to contact us directly through our website. We offer free initial consultations to all injured workers and we will not collect a legal fee unless we win your case. From our office in Philadelphia, we are proud to fight for the legal rights and financial interests of injured workers throughout Pennsylvania.