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Court: injured worker who was unable to afford bail and subsequently incarcerated can’t be denied comp benefits

The Commonwealth Court of Pennsylvania on Wednesday ordered workers’ compensation benefits to be reinstated and recalculated for a worker who served time in jail after being injured at the workplace.

In 2012, Carl Sadler suffered an injury at the Philadelphia Coca-Cola Bottling Co., Inc., and later began receiving workers’ compensation benefits. In 2013, Sadler was arrested and held on $150,000 bail, which he was unable to post. He was incarcerated for 525 days until being released at trial after being sentenced to time served.

In 2015, Philadelphia Coca-Cola Bottling Co., Inc. filed to have Sadler’s workers’ compensation benefits suspended, arguing that the sentence of time served counted as “incarceration after conviction,” making him ineligible to continue receiving benefits.

Sadler appealed, but a Workers’ Compensation Judge and later the Pennsylvania Workers’ Compensation Appeal Board ruled in favor of his employer. The Commonwealth Court of Pennsylvania overturned those rulings, and also ordered that Sadler’s benefits be recalculated to include overtime that he had worked.

“I think this is a correct reading of state law,” said Sadler’s attorney, Richard Jaffe of the Law Offices of Richard A. Jaffe LLC in Philadelphia. “My client was unable to post bail. The Legislature did not intend for the Worker’ s Compensation Carrier to be entitled to a Suspension of Mr. Sadler’ s Benefits while he remained incarcerated only due to the fact that he was unable to afford bail. Taking into account the strict meaning of Section 306 (a.1)  of the Act, in no way was Claimant “ unjustly enriched”  as suggested by the Defendants Petition as there is no basis, under the law, to Grant a Suspension of Claimant’ s Benefits as he was not incarcerated even one day after a conviction. Rather, it was the Claimant who suffered undue prejudice due to his inability to afford the amount of bail set by the Courts in New Jersey.

One will never know what Petitioner Sadler’ s actual sentence would have been had he been able to afford Bail and ultimately entered into a Plea deal. As Petitioner was already deprived of his liberty solely because he was unable to post bail, to allow the Employer to have a credit against Petitioner’ s entitlement to future Workers Compensation Benefits  would also present a serious question of denial of Equal Protection of the laws under the 14th Amendment”

The case is Carl Sadler v. Workers’ Compensation Appeal Board (Philadelphia Coca-Cola).

About the Law Offices of Richard A. Jaffe, LLC

For more than 30 years, Philadelphia attorney Richard A. Jaffe has been fighting for the rights of injured workers in Pennsylvania. Attorney Jaffe handles cases involving workers’ compensation, construction accidents and Social Security disability.

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