Master PA Workers’ Comp Injury Relationship
Causal Relationship In PA Workers’ Comp Claims
PA Workers’ Compensation law requires an injury to have a causal relationship with the employment. Often referred to as “arising in the course of employment” and “related thereto.” This blog discusses the meaning of these terms, how courts interpret them, and what injured workers need to know.
To qualify for workers’ comp an injury must arise from and relate to employment.
What Does “Arising In The Course Of Employment” Mean?
Arising in the course of employment means the injury must arise out of employment. The onset of the injury may occur during the employment, such as a forklift running over a worker’s foot. Or, the circumstances that cause the condition may occur in the scope of employment, such as an occupational disease.
If an accident occurred outside work with no relation to the job, it would not fall under workers’ comp. In addition, workers’ compensation covers workplace injuries that occur while working for an employer. Workers’ compensation insurance does not generally cover injuries to an independent contractor.
How Have Courts Interpreted This Requirement?
Determining whether an injury meets the criteria can get complicated. Cases such as O’Rourke v. WCAB and Marazas v. WCAB discuss these principles.
O’Rourke v. WCAB
In this case, the PA Supreme Court dealt with a unique workers’ comp claim. Laura O’Rourke sought benefits after her son, Joshua Gartland, attacked her while she slept at home. Under a state-funded program, O’Rourke worked as an employee for her son, caring for him. He suffered from serious health problems from long-term drug use.
While in her home, O’Rourke suffered a brutal stabbing by her son. The court had to determine if her injuries qualified for compensation under the Workers’ Comp Act.
The Supreme Court concluded that the injuries did not arise in the course of employment nor were they related thereto. They determined that the nature of her employment did not require overnight care during the attack.
Marazas v. WCAB
This case went up to the Commonwealth Court of PA. Marazas, employed as a driver technician, reported to work tired after an on-call weekend. Because of this, he requested a reduction in his workload for the day.
His manager refused and Marazas resigned. While removing his personal belongings from the company truck as instructed, Marazas tripped over a pallet jack. This occurred on the employer’s premises and resulted in Marazas sustaining injuries.
The Commonwealth Court of PA awarded Marazas workers’ compensation benefits. Marazas occupied the employer’s premises and carried out a task under the employer’s direction at the time of injury.
What Does “Related Thereto” Mean?
Related thereto examines whether the injury has a direct connection to the employment, medical or otherwise. The Workers’ Compensation Act 61 of 1972 introduced the “related thereto” requirement. It added another layer in determining what qualifies as a work injury.
What Have The Courts Said?
Krawchuk v. Philadelphia Electric Co.
Krawchuk v. Philadelphia Electric Co. significantly expanded this interpretation of work relatedness. The Pennsylvania Supreme Court ruled that the actual onset of an injury does not need to occur at work. However, the circumstances causing the condition must occur in the scope of employment and relate thereto.
In this case, the PA Supreme Court addressed the claim of Rosemarie Krawchuk, the widow of John Krawchuk, who worked as an electrical engineer. He died from a heart attack after working under great stress because of his employment. The heart attack occurred at his home, following a period of intense work related to a special project known as “PMS4.” He also had to prepare for a treatise he had to deliver in California.
The PA Supreme Court reversed lower courts’ decisions and awarded death benefits. They interpreted the Act to include job-related heart attacks, occurring off the employer’s premises. Providing, the injury arises in the course of employment and relates thereto.
Medical Connection
In situations with a medical connection, one must establish a clear and certain link. This must show a connection between the injury and the job duties or conditions. Courts look to clear medical testimony to establish this causal relationship between the injury and employment.
Non-Medical Connection
Sometimes, the situation lacks a medical basis. In these situations, the courts look for evidence that the injury would not have occurred “but for” the employment. When the job puts the worker in the situation that leads to the injury, the courts may consider it work-related.
The “but for” test applies for incidents that occur outside traditional work environments. For example, injuries sustained while traveling for work or activities indirectly related to the worker’s job.
Weaver v. WCAB and Morgan v. Giant Markets, Inc. expanded the “related thereto” requirement. When the causal connection appears obvious, unequivocal medical testimony becomes unnecessary.
What Does This Mean For Workers?
This broadens the definition of “work-related injury.” Workers must establish a clear link to their work conditions or activities, showing the injury arose out of employment. Conditions covered by workers’ comp include when an accident arises because of work-related stress or activities. Even if the physical onset does not occur in the course of employment and happens elsewhere.
This helped with issues including occupational diseases, aggravation of pre-existing conditions, and repetitive conditions, like carpal tunnel syndrome.
Final Thoughts
For injured workers, understanding the terms “arising in the course of employment” and “related thereto” proves critical. They cover a wide range of injuries. Some injuries arise directly at work to those with a more indirect connection to employment. These legal standards determine the eligibility for compensation in PA.
Workers suffering wage losses for their work injuries need a lawyer. If you have questions about your injury or what qualifies as a work injury, speak with a lawyer. Reach out to our offices 24/7 for a free and confidential consultation (215) 609-4183.
