PA case questions Good Samaritan provision of workers’ comp law

A case in Pennsylvania questions whether Good Samaritan actions disqualify a worker from workers' compensation benefits.

A case out of Pennsylvania is gaining attention throughout the legal community. The case is unique as it addresses the Good Samaritan provision of the workers' compensation laws in the state.

The case involves contract work to install pipelines and manholes for a local sanitation plant. While working, an employee, Pounds, heard a call for help from a fellow worker. Pounds responded, coming to the aid of a man who had fallen into a nearby concrete pit. When Pounds arrived, the man was lying motionless at the bottom of the pit.

Pounds had worked in the pit on previous occasions, and descended into it by way of ladder to offer assistance. Upon reaching the injured man, it was apparent that the man had died from the fall. Pounds attempted to climb out of the pit, however when he had climbed up approximately 20 feet he lost consciousness due to exposure to methane gas. Pounds fell from the ladder to the ground. He suffered multiple injuries, including injuries to his left leg, ribs, back and lungs.

Legal battle

The case, Pipeline Systems, Inc. v. WCAB (Pounds), questions whether the employee was entitled to workers' compensation benefits when injured while acting as a Good Samaritan. Workers' compensation benefits are available specifically to those who are injured in the course of employment. The employer attempted to argue that Pounds was not acting in the course of employment as he left his assigned station to offer assistance to his injured co-worker. As a result, the employer argued they did not have to provide workers' compensation benefits.

The Workers' Compensation Judge held in favor of the employee. The Workers' Compensation Appeals Board (WCAB) affirmed. The Employer, Pipeline Systems, Inc, along with the workers' compensation insurance provider Continental Western Insurance Company petitioned for review of the WCAB holding. The Commonwealth Court of Pennsylvania reviewed the case.

The Court clarified that workers' compensation benefits are provided for injures that arise "in the course of employment." This includes injuries "sustained in furtherance of the business or affairs of the employer, as well as other injuries which occur on premises occupied or controlled by the employer." The Court interpreted the Good Samaritan provision of the Workers' Compensation Act at Section 601(a)(10)(i)-(ii) of the Act. Ultimately, it found that "...the statute necessarily requires the conclusion that attempts to render aid to another do not, in and of themselves, constitute an abandonment of employment." Thus, Pound's actions did not "constitute an abandonment of employment." As a result, he was within the scope of employment and entitled to benefits.

Implications of this case

This case provides an example of the many intricacies tied to worker's compensation cases. Even when an injury appears to clearly qualify for benefits, insurance providers and employers may attempt to find a loophole to get out of making payments. As a result, it is wise for those who are injured while on-the-job to seek the counsel of an experienced workers' compensation attorney. This legal professional will advocate for your rights, working to better ensure you receive the benefits to which you are entitled.