Pennsylvania Appeals Court Affirms State Court Lacks Jurisdiction over Employee Injured Outside of Pennsylvania
In a recent case before the Pennsylvania Commonwealth Court, the court addressed the issue of awarding workers’ compensation benefits for extraterritorial work-related injuries. Here, William Watt’s claim for workers’ compensation was denied and dismissed on the grounds that it lacked jurisdiction. Mr. Watt (Claimant) argued that the Workers’ Compensation Judge erred when they held his employment was not principally localized in Pennsylvania. Claimant also argued his employment contract, stating his principal employment location as Alabama, was unenforceable and against public policy.
After allegedly suffering a work-related injury in New Jersey, Claimant filed a claim petition against his employer, Boyd Brothers Transportation (Employer). Claimant is an interstate truck driver, and Employer argued that Pennsylvania did not have jurisdiction on the grounds that Claimant was not hired or injured in the state, and he received workers’ compensation benefits in Alabama, per the terms of his employment contract. The Workers’ Compensation Judge conducted hearings.
Claimant testified that he had lived in Pennsylvania almost his entire life and was a Pennsylvania resident. The evidence demonstrated that Claimant spent significant hours driving his truck for Employer in Pennsylvania.
In opposition, Employer presented the Workers’ Compensation Agreement signed by Claimant, which made clear that Alabama workers’ compensation laws apply to the agreement. Employer and Claimant agreed that all workers’ compensation claims for work-related injuries are governed by the laws of Alabama. The Workers’ Compensation Judge found that Claimant’s employment was localized in Alabama and that he lacked jurisdiction over Claimant’s claim petition. The petition was denied and dismissed, and Claimant appealed to the Board, which affirmed.
On appeal, Claimant argued the totality of facts leads to the conclusion that his employment was localized in Pennsylvania, where he lived and worked. He also contended the Workers’ Compensation Judge erred in relying on the agreement because the agreement’s choice of law provision violates public policy and is unenforceable.
Under the Pennsylvania Workers’ Compensation Act, an employee injured outside the state is entitled to benefits that he would have been entitled to had the injury occurred within the state, if his employment is principally localized in the state.
To determine principal location, the employer must have a business in the state, or the employee must work from the state, or if neither, the employee must be domiciled and spend substantial working time in the service of his employer in the state.
The issue before the court was whether Claimant spent a substantial part of his working time in Employer’s service within the state of Pennsylvania. Claimant contended that he kept his truck in the state and drove many working hours in the state. But on appeal, the court stated Claimant did not spend a substantial part of his working time in Pennsylvania.
Regarding the Workers’ Compensation Agreement, and Claimant’s assertion that the choice of law provision is unenforceable, the appellate court analyzed Pennsylvania case law on the issue. In this case, Claimant was injured outside the boundaries of Pennsylvania. His employment was not principally localized in the state. He was not otherwise qualified for workers’ compensation benefits under the Act. Based on these facts, the agreement did not abridge Claimant’s rights under the Act or otherwise violate public policy. It was not error for the Workers’ Compensation Judge to rely on the agreement and determine that the principal employment location was Alabama.
Claimant also challenged the constitutionality of the Pennsylvania Workers’ Compensation Act, on the grounds that there are not enough significant contacts in Alabama to outweigh Pennsylvania’s interest. The court assessed the as-applied challenge to the law and stated that it fails because Claimant was not injured in Pennsylvania. His employment was not localized in the state, and therefore the state’s interest was not undermined because he was not entitled to benefits for his injury.
In conclusion, since Claimant’s employment was not principally localized in Pennsylvania, he was not entitled to benefits in the state for an extraterritorial injury. Under his Workers’ Compensation Agreement, his employment was localized in Alabama, and the agreement did not violate public policy. The court affirmed the finding that Pennsylvania lacked jurisdiction over the claim.
More Blog Posts:
Pennsylvania Commonwealth Court Holds that Employer is not Required to Secure Claimant’s Agreement on Physician, Scranton Personal Injury Lawyer Blog, July 27, 2015
Commonwealth Court Reinstates Workers’ Compensation Judge’s Ruling in Favor of Injured Driver, Scranton Personal Injury Lawyer Blog, September 29, 2014