This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A dock worker fell from a step stool while unloading merchandise, aggravating a preexisting severe osteoarthritis condition in his left hip. The fall occurred during the course of his employment, and the worker was subsequently restricted to sedentary work. The employer initially paid medical and indemnity benefits but ceased all payments in January 2009, prompting the worker to file a claim (paras headnotes, [DS 2], [RP 177-178]).
Procedural History
- Workers’ Compensation Administration, November 9, 2009: The Workers’ Compensation Judge (WCJ) found the worker had a 100% ongoing disability caused by the aggravation of his preexisting condition and awarded compensation (paras [RP 176], [RP 180]).
- Workers’ Compensation Administration, February 19, 2010: The WCJ determined the employer acted in bad faith by ceasing payments without a reasonable basis and increased the worker’s benefits by 25% (paras [RP 244-245]).
Parties' Submissions
- Employer/Insurer (Appellant): Argued that the law requiring payment for the aggravation of preexisting conditions should be overturned. Claimed that asking the court to revisit precedent does not constitute bad faith and that it relied on a medical letter to justify ceasing payments (paras [MIO 1-2], [RP 198], [RP 232]).
- Worker (Appellee): Asserted that the employer lacked a good faith basis to deny the claim, as the aggravation of preexisting conditions is clearly covered under the Workers’ Compensation Act. Highlighted that all treating physicians confirmed the causal link between the fall and the aggravated condition (paras [RP 232], [RP 244-245]).
Legal Issues
- Did the employer act in bad faith by ceasing payments to the worker without a reasonable basis?
- Is the employer liable for the aggravation of the worker’s preexisting condition under the Workers’ Compensation Act?
Disposition
- The Court of Appeals affirmed the WCJ’s determination of bad faith and the 25% increase in the worker’s benefits (paras headnotes, [RP 244-245]).
Reasons
Per Sutin J. (Robles and Vanzi JJ. concurring):
The Court found that the employer lacked a reasonable basis to discontinue payments, as it was aware that the worker’s fall aggravated his preexisting condition, which is covered under the Workers’ Compensation Act. The employer’s reliance on a medical letter was insufficient, as the letter acknowledged the aggravation caused by the fall. The employer’s argument to overturn established precedent was rejected, as the Court is bound by Supreme Court rulings and found no policy concerns with the current law. The employer could have pursued alternative legal avenues, such as paying benefits under protest or seeking a stay, rather than ceasing payments entirely. The Court also noted that the employer abandoned its argument regarding additional discovery by failing to address it in its memorandum in opposition (paras [RP 198], [RP 232], [RP 244-245], [MIO 1-2]).