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Sadler v. Philadelphia Coca-Cola (Workers Comp. Appeal Bd.

Pennsylvania Commonwealth Court

January 7, 2022

After adverse rulings from a Workers’ Compensation Judge and Workers’ Compensation Appeal Board, a claimant petitioned for review in the Commonwealth Court claiming that his employer should not have been permitted to terminate his workers’ compensation benefits. The Commonwealth Court affirmed, holding (1) Section 204(a) of the Workers’ Compensation Act, which sets forth an offset for the receipt of Social Security old-age benefits, does not violate the Equal Protection Clauses of the United States and Pennsylvania Constitutions because it is rationally related to a legitimate government interest – cost containment – and is a reasonable means of achieving that interest; (2) the WCJ did not err in relying on the labor market survey earning assessment, and deposition testimony of the employer’s vocational expert; (3) the WCJ did not err in not considering claimant’s status as a Class II felon when determining whether a position was appropriate and/or open and available to claimant; and (4) the WCJ’s met the reasoned decision requirements of Section 422(a) of the Act.

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