Moore v. Workers' Compensation Appeal Board

Dissenting Opinion by

Judge FRIEDMAN.

I respectfully dissent. The majority holds that Brian Moore (Claimant), while subject to electronic home monitoring (EHM) in West Virginia, was “incarcerated” under section 306(a.l) of the Workers’ Compensation Act (Act)1 and, therefore, was not entitled to workers’ compensation benefits for the period of EHM. In so holding, the majority reasons that, although Claimant was eligible for work release, EHM significantly limited Claimant’s movements, such that he was in constructive custody.2 (Majority *635op. at 5.) I cannot accept the majority’s holding because it is inconsistent with our supreme court’s construction of section 306(a.l) of the Act and because it is contrary to Pennsylvania case law relating to EHM.

I. Section 306(a.l)

The Act does not define the meaning of the word “incarcerated” in section 306(a.l) of the Act. Because of the ambiguity of the term, Pennsylvania courts have had to address whether the term refers only to confinement in a jail or prison, whether the term is broad enough to include confinement in a psychiatric hospital, and whether the term encompasses residing in a halfway house with work release privileges. See Henkels & McCoy, Inc. v. Workers’ Compensation Appeal Board (Hendrie), 565 Pa. 493, 776 A.2d 951 (2001); see also Flynn v. Workers’ Compensation Appeal Board (Sovereign Staffing Source, Inc.), 776 A.2d 1043 (Pa.Cmwlth.), appeal denied, 567 Pa. 749, 788 A.2d 380 (2001); Brinker’s International, Inc. v. Workers’ Compensation Appeal Board (Weissenstein), 721 A.2d 406 (Pa.Cmwlth.1998).

Of course, the object of all statutory construction is to ascertain and effectuate the intention of the General Assembly. Section 1921(a) of the Statutory Construction Act of 1972, 1 Pa.C.S. § 1921(a). Where, as here, the words of a statute are not explicit, courts may ascertain the intention of the General Assembly by considering, among other matters, the object to be attained. Section 1921(c)(4) of the Statutory Construction Act of 1972, 1 Pa.C.S. § 1921(c)(4). With that in mind, I turn to our supreme court’s discussion of the purpose of section 306(a.l) of the Act.

In Banic v. Workmen’s Compensation Appeal Board (Trans-Bridge Lines, Inc.), 550 Pa. 276, 286, 705 A.2d 432, 437 (1997), our supreme court stated, “we view [section 306(a.l) of the Act] ... as nothing more than a clarification that a claimant cannot receive benefits while he [is] incarcerated .... ” Our supreme court explained that, under the law as it existed prior to the enactment of section 306(a.l) of the Act, benefits were permitted only when a claimant’s work-related injury resulted in a loss of earning power. Id. Thus, benefits were suspended when a claimant was incarcerated because the work-related injury was no longer the cause of the claimant’s loss of earning power. Id. In other words, the enactment of section 306(a.l) of the Act simply made it clear that, where incarceration is the cause of a claimant’s loss of earning power, the claimant is not entitled to benefits.3

Thus, the General Assembly intended for the word “incarcerated” to mean “incarcerated in a manner that causes a loss of earning power.” Clearly, then, under section 306(a.l) of the Act, a claimant is not entitled to benefits where he is incarcerated in a manner that causes a loss of *636earning power. However, where a claimant is incarcerated and eligible for work release, i.e., where his incarceration does not cause a loss of earning power, the claimant is entitled to benefits when a work-related injury prevents the claimant from participating in work release.

This position is supported- by Henkels & McCoy, in which our supreme court provided further guidance regarding the object to be attained by section 306(a.l) of the Act.

It is evident that the legislature sought to preclude the payment of workers’ compensation benefits to persons who are convicted of violations of the Pennsylvania Crimes Code and who, as a result of those convictions, are thereafter removed from the workforce.

Henkels & McCoy, 565 Pa. at 500, 776 A.2d at 955 (emphasis added). This language clearly indicates that the General Assembly intended for the word “incarcerated” to mean “incarcerated in a manner that removes one from the work force.” Thus, where an incarcerated claimant is eligible for work release, so that the incarceration has not removed the claimant from the work force, the claimant is entitled to benefits when a work-related injury prevents the claimant from participating in work release and earning wages as a member of the work force.

In short, a claimant is entitled to benefits when a work-related injury removes a claimant from the work force, causing a loss of earning power. Applying these principles to Claimant, it is apparent that he remained eligible for benefits notwithstanding his “incarceration.” Here, because Claimant was on EHM and was eligible for work release, he was not incarcerated in a manner that caused a loss of earning power or in a manner that removed him from the work force. Instead, Claimant’s work-related injury caused his loss of earning power and prevented him from being a member of the work force; accordingly, Claimant is entitled to benefits.

II. Electronic Home Monitoring

The majority reaches a contrary conclusion by reasoning that EHM constitutes “incarceration” under section 306(a.l) of the Act because EHM significantly limits a person’s movements, keeping the person in constructive custody. However, the majority’s reasoning ignores prior case law holding that EHM does not significantly limit a person’s movements and does not constitute custody.

In Commonwealth v. Chiappini, 566 Pa. 507, 782 A.2d 490 (2001) (plurality), our supreme court addressed whether a person on EHM is in custody under section 9760(1) of the Sentencing Code, 42 Pa.C.S. § 9760(1), such that the person is entitled to credit against a prison term for time spent on EHM. The court was divided on this issue. Justice Zappala wrote the lead opinion, joined by Chief Justice Flaherty and Justice Newman, concluding that the time one spends on EHM is time spent in custody because EHM programs severely limit a person’s freedom.

Justice Nigro concurred in the result reached by the three justices based on equity and the particular facts of the case. Id. (Nigro, J., concurring). However, Justice Nigro disagreed that EHM constitutes custody under section 9760(1) of the Sentencing Code, stating, “I generally frown upon a process that allows people to serve sentences in the comforts of their own home.” Id. at 527-28, 782 A.2d at 502. Justice Cappy, Justice Castille and Justice Saylor each wrote separate opinions, agreeing with Justice Nigro that a person in an EHM program is not in custody.

A defendant in a home confinement program is free to move about in his home, *637eat, watch television, sleep in his own bed, socialize with family and friends and otherwise enjoy the comforts of his home at will. Being told the judicial equivalent of “go to your room” in no way approaches being ordered to pack a few belongings, leave that home, and report to a prison cell.

Id. at 531-32, 782 A.2d at 504 (Castille, J., concurring and dissenting). Thus, four justices on our supreme court have concluded that EHM does not significantly limit a person’s movements and does not place a person in custody.

One month before our supreme court filed Chiappini, this court held that EHM does not constitute custody for purposes of section 9760(1) of the Sentencing Code. Jackson v. Pennsylvania Board of Probation and Parole, 781 A.2d 239 (Pa.Cmwlth.2001). This court’s position is consistent with that of the four justices in Chiappini who reasoned that the restrictions of EHM were not sufficient to make confinement at home custody. Id.

Inasmuch as this court and four justices of our supreme court have concluded that the restrictions on a person on EHM are not significant enough to constitute custody, I cannot accept the majority’s inconsistent view. Accordingly, I would reverse.

. Act of June 2, 1915, P.L. 736, added by section 4 of the Act of June 24, 1996, P.L. 350, 77 P.S. § 511.1. This particular provision of the Act states that "[njothing in this [A]ct shall require payment of compensation ... for any period during which the employe is incarcerated after a conviction....” 77 P.S. § 511.1.

. The majority also considers the fact that Claimant could have been charged with escape in West Virginia for leaving his home without authorization. I note that this matter is not yet settled in Pennsylvania. On Febru*635ary 6, 2002, our superior court filed an opinion holding that a person on EHM may be charged with escape under section 5121 of the Crimes Code, 18 Pa.C.S. § 5121, for leaving home without authorization. Commonwealth v. Wegley, 791 A.2d 1223 (Pa.Super.), appeal granted, 569 Pa. 706, 805 A.2d 524 (2002). However, on July 30, 2002, our supreme court granted a petition for allowance of appeal and is now reviewing the matter.

. Our supreme court noted that, before the passage of section 306(a.l) of the Act, an employer sought to suspend the payment of benefits to an incarcerated claimant by presenting evidence of available jobs that the employer referred to the claimant. Id.; see Kachinski v. Workmen's Compensation Appeal Board (Vepco Construction Co.), 516 Pa. 240, 532 A.2d 374 (1987). Since the addition of section 306(a.l) of the Act, it is no longer necessary for an employer to produce such evidence.