Attorney Dan Siegel Secures Pa. Supreme Court Victory on Specific Loss Benefits Under Workers’ Compensation Act
In Steets v. Celebration Fireworks, Inc., the Pennsylvania Supreme Court held on May 30, 2025 that an injured worker is entitled to specific loss benefits under the Workers’ Compensation Act (WCA) after her death from work-related injuries. The decision overturns more than two decades of cases barring such a recovery.
Key Points:
- Background: Steets was injured in 2017 and received total disability benefits. She later sought specific loss benefits for additional injuries, which were awarded by a Workers’ Compensation Judge (WCJ). However, Steets died in 2020 while the employer was appealing the award.
- Legal Issue: The court examined whether specific loss benefits survive the death of a worker who dies from work-related injuries, particularly when the claim was still under appellate review at the time of death.
- Majority Opinion:
- The court overruled prior decisions (Estate of Harris and Burns) that limited the survivability of specific loss benefits to cases where the worker died from non-work-related causes.
- It held that Section 410 of the WCA allows specific loss benefits to be paid to the estate if the worker dies before the final adjudication of their claim, regardless of the cause of death.
- The case was remanded to determine the amount of specific loss benefits owed to Steets’ estate.
- Dissenting Opinions:
- Justice Wecht argued that Section 410 only applies to compensation due before the claimant’s death, not future specific loss benefits that were not yet payable. He maintained that the estate is not entitled to these benefits.
- Justice Brobson agreed, emphasizing that specific loss benefits were not “due” to Steets at the time of her death because she was still receiving total disability benefits.
- Outcome: The court ruled in favor of Steets’ estate, allowing the recovery of specific loss benefits under Section 410.
This decision clarifies the interpretation of the WCA, expanding the circumstances under which specific loss benefits can survive a worker’s death.
Contact Us:
Our office is dedicated to fighting for injured workers to receive the wage loss and medical benefits they deserve. If you have a claim or think you do, call us at 610-446-3457 or email us to set up a consultation with one of our attorneys. We will guide you through the process and fight for your recovery.
