In Sadler v. Workers’ Comp. App. Bd., the Pennsylvania Supreme Court determined that the Workers’ Compensation Act permits beneficiaries to receive benefits while in pre-conviction incarceration. In this case, the employee was injured, and the employer acknowledged he was entitled to a weekly disability wage. But soon thereafter, the employee was arrested. Unable to post bail, the employee remained incarcerated for 525 days until he pleaded to a time-served sentence and was immediately released. The employer claimed that the employee was not entitled to the benefits while incarcerated. The employee disagreed, arguing that Section 306(a.1) of the Workers’ Compensation Act prohibited benefits for time spent in post-conviction custody, and he only spent time in jail pre-conviction. In a short, unanimous opinion, the Supreme Court agreed with the employee, noting that the Act clearly states that benefits are not required “for any period during which the employee is incarcerated after a conviction[.]”
