On April 19, 2023, the Pennsylvania Supreme Court issued a significant decision, which enforced the Pennsylvania Workers’ Compensation Act’s Exclusivity provision.
In its opinion, the court addressed employers’ immunity in personal injury civil litigation matters. KingSpry’s Employment Law Chair, Avery E. Smith, details the Court’s opinion in Franczyk v. The Home Depot, Inc.
Case Details
While working at Home Depot, Plaintiff, Lindsay Franczyk, was bitten by a customer’s dog. Franczyk reported the incident to her supervisors, who allegedly barred her from contacting the dog owner or any other witnesses.
After investigation, the supervisors were unable to obtain contact information for the customer or the dog. As a result of the dog bite, Franczyk developed cubital tunnel syndrome, which required surgery. Following a workers’ compensation claim, Franczyk received benefits.
Later, Franczyk sued Home Depot and her supervisors, asserting that their acts and omissions denied her the opportunity to file a third-party suit against the dog owner. She alleged that the failure to adequately investigate the incident and obtain contact information prevented her from pursuing a claim.
Home Depot claimed immunity under the Pennsylvania Workers’ Compensation Act’s (“WCA”) exclusivity provision, however, the Allegheny County Court of Common Pleas denied its motion and ruled in favor of Franczyk. The Home Depot appealed.
What was the Issue?
On appeal, the Pennsylvania Supreme Court reviewed whether an employee who suffers a workplace injury attributable to a non-employer third party is precluded by the Exclusivity provision from bringing a tort claim against the employer.
What was the Answer?
The Court succinctly responded to this question, finding that the worker’s compensation system is a compromise that, in exchange for a no-fault insurance system, grants employers immunity from tort liability for workplace injuries. Therefore, Franczyk could not sue Home Deport for allegedly failing to investigate the incident as she had already received workers’ compensation benefits.
What is the Exclusivity Provision?
The WCA Exclusivity provision provides: “liability of an employer under this act shall be exclusive and in place of any and all other liability to such employees … entitled to damages in any action at law or otherwise on account of any injury or death…”
In simple terms, employees cannot sue an employer for a work-related injury as long as they are receiving benefits from workers’ compensation. The PA Supreme Court’s decision upheld this principle.
Takeaways for Employers
The decision in Franczyk affirms the enforcement of the Exclusivity provision of WCA. This decision protects employers from being forced to defend against lawsuits where an employee makes allegations against them for failing to investigate workplace injury and impeding their ability to recover against third-party tortfeasors.
KingSpry’s Employment Law attorneys assist employers of all sizes to proactively and responsibly manage their employment and human resources needs. If you have questions about Workers’ Compensation or employment needs, click here to contact a member of our employment group.
