Carl Sadler vs. WCAB- Pennsylvania Supreme Court Court Case Regarding Pre-Conviction Incarceration and Suspension of Workers’ Compensation Benefits
On January 27, 2021, Justice Donohue for the Pennsylvania Supreme Court issued an Opinion, finding that the Employer- Philadelphia Coca-Cola Company- was not entitled to a reimbursement of benefits during Claimant’s pre-conviction incarceration. Sadler was hurt at work in July 2012- losing his pinky finger, and hurting his back. In August 2013, he was charged with a crime in NJ. He couldn’t post bail and served 525 days. At sentencing, he pled guilty and was released for time served. Employer then filed a Petition to Suspend benefits that he received while in jail. It argued he was unjustily enriched.
The petitions were heard by a workers’ compensation judge, who concluded that PCCC was entitled to reimbursement for benefits paid to Sadler during his pre-conviction incarceration. The judge did not provide for a future credit against benefits to be paid to Sadler, but rather ordered that PCCC should petition the Supersedeas Fund for reimbursement. PCCC appealed to the Workers’ Compensation Appeals Board and Sadler cross-appealed. The Board modified the workers’ compensation judge’s decision by allowing PCCC to seek a credit against Sadler’s future payments, but affirmed in all other respects.
The Commonwealth Court agreed with Sadler that because he spent no time in jail after his conviction, his benefits were improperly suspended. The Pennsylvania Supreme Court agreed. They pointed to the clear, umambiguous language under Section 306 (a.1) of the Pennsylvania Workers’ Compensation Act which reads in part: “nothing under this Act shall require payment of compensation under clause (a) or (b) for any period during which the employee is incarcerated after conviction.”
The Supreme Court of Pennsylvania noted that this is a simple matter of statutory interpretation and the plain language should govern. This was the right result. The language is clear and not ambiguous. Furthermore, looking at Equal Protection principles- a person is presumed innocent until proven guilty- so a pre- conviction incarceration doesn’t mean guilty. The purpose of the Section 306 language is to not award benefits to a person who has voluntarily removed themselves from the workforce. Here, Sadler was incarcerated because he couldn’t make bail.
If you have any questions about this case, or any other Pennsylvania Work Comp issue, please contact us.