Mitchell v. Workers' Compensation Appeal Board

NARICK, Senior Judge.

The issue presented is whether Andrew M. Mitchell’s (Claimant) failure to respond to notification of available employment because of his incarceration constitutes bad faith for purposes of suspending workers’ compensation benefits pursuant to Kachinski v. Workmen’s Compensation Appeal Board, 516 Pa. 240, 532 A.2d 374 (1987). We hold that incarceration is not a valid justification for failing to respond to job notices. Therefore, the order of the Board is affirmed.

The facts of this case are as follows. On May 12, 1986, Claimant sustained an injury while working for Employer. Employ*946er accepted liability for this injury and issued a notice of compensation payable, pursuant to which Claimant received total disability benefits at the rate of $173.50 per week, based upon an average weekly wage of $200.00.

Pursuant to a criminal conviction Claimant was incarcerated in Somerset, Pennsylvania from October 30, 1991 until March 30, 1995, when he was released on parole. Claimant was again incarcerated on July 30, 1995 as a result of a parole violation. Claimant remained incarcerated from July 30, 1995 until November 18, 1996, when he was again released on parole.

Employer initiated vocational efforts in August 1995, while Claimant was incarcerated. Employer’s vocational consultant sent three job referral letters to Claimant’s counsel in Philadelphia. All three job referrals were for positions within Claimant’s physical restrictions. Claimant did not make a good faith response to these job referrals. Claimant did not respond to the job referrals because he was incarcerated.

After his release in November 1996 Claimant notified Employer of his willingness to submit to vocational referrals. Employer did not respond to this request. Instead, on or about October 27, 1995, Employer filed a petition to terminate, suspend or modify compensation benefits. After a hearing, a Worker’s Compensation Judge (WCJ) found that Employer was entitled to a suspension from July 30, 1995 through November 17, 1996 based upon Claimant’s incarceration. The WCJ also found Employer was entitled to a suspension as of November 1, 1995 based upon Claimant’s earning capacity of $200.00 per week as of that date.

Claimant appealed the decision of the WCJ to the Workers’ Compensation Appeal Board (Board). The Board affirmed the order of the WCJ. Claimant then filed a petition for review with this Court.

On appeal,1 Claimant concedes that Employer is entitled to a suspension of benefits during the period of Claimant’s incarceration pursuant to Section 306(a)(2) of the Workers’ Compensation Act,2 but argues that Claimant was entitled to a reinstatement of benefits upon his release in November 1996. Specifically, Claimant argues that the good faith requirement imposed upon him in Kachinski v. Workmen’s Compensation Appeal Board, 516 Pa. 240, 532 A.2d 374 (1987), should be suspended until Claimant is released from incarceration. We disagree.

In Kachinski, the Pennsylvania Supreme Court set out guidelines to determine whether benefits may be modified where work is available for a previously disabled claimant. The employer must first prove a change in the claimant’s condition. Id. The employer must then demonstrate that there is a job available for the claimant that the claimant is physically able to perform. Id. If the claimant can not demonstrate that he followed through in good faith, benefits can be modified. Id.

Claimant cites Banic v. Workers’ Compensation Appeal Board, 550 Pa. 276, 705 A.2d 432 (1997), and Brown v. Workmen’s Compensation Appeal Board, 134 Pa.Cmwlth. 31, 578 A.2d 69 (1990), for his argument that Employer is not entitled to ongoing suspension of Claimant’s benefits because it met the Kachinski requirements while Claimant was still in prison.

In Brown, this Court suspended the claimant’s benefits based on the finding that the employer established that the claimant had recovered sufficiently to be returned to an available job and that the claimant’s incarceration was preventing him from performing the job. Brown does *947not say that if the claimant is released from incarceration the employer would again have to meet the requirement set forth in Kachinski to continue the suspension of benefits.

In Banic, the Supreme Court held that since the claimant was incarcerated, the employer could suspend his benefits without proving the requirements set forth in Kachinski. The Court did not hold that an employer was prevented from establishing the requirements in Kachinski while the claimant was incarcerated. To the contrary, the Court cited with approval Brown and Wheeling Pittsburgh Steel Corp. v. Workmen’s Compensation Appeal Board, 38 Pa.Cmwlth. 370, 395 A.2d 586 (1978) (convicted felon not entitled to benefits where employer showed that were claimant not in prison there would be work available ho him which he could perform with no loss of earnings.)

We hold there is no authority for the argument that an employer must wait for a claimant to be released from incarceration before it can satisfy the requirements to suspend benefits pursuant to Kachinski. In the case at bar, Employer established all the requirements set forth in Kachinski and thus is entitled to a suspension of Claimant’s benefits.

Finally, Claimant argues that the offered positions were not “available” to Claimant because Claimant was incarcerated in Somerset, Pennsylvania and the jobs were located in Philadelphia, Pennsylvania. We disagree.

Claimant never notified the Workers’ Compensation Bureau of a change in address to the prison in Somerset, Pennsylvania. Also, after being released from prison on both occasions, Claimant returned to Philadelphia. Thus, the WCJ properly found that the job referrals to positions in Philadelphia were appropriate.

Accordingly, the order of the Board is affirmed.

ORDER

AND NOW, this 26th day of July, 1999, the order of the Workers’ Compensation Appeal Board in the above-captioned matter is hereby affirmed.

. Our scope of review is limited to determining whether there has been a violation of constitutional rights, an error of law, or that necessary findings of fact are not supported by substantial evidence. Brown v. Workmen’s Compensation Appeal Board, 134 Pa.Cmwlth. 31,578 A.2d 69 (1990).

. Act of June 2, 1915, P.L. 736, as amended 77P.S. § 511(2).