Legal Opinion · Concurrence

Panyko v. Workers' Compensation Appeal Board

Supreme Court of Pennsylvania

Decided December 28, 2005No. 37 WAP 2004Published

1ConcurrenceJustice Saylor

I agree with the majority that the abnormal working conditions requirement should not extend to situations in which a claimant suffers a physical injury, such as a heart attack, as a result of a psychic or mental stimulus arising in the work environment. Indeed, when the General Assembly amended the Workers’ Compensation Act in 1972 to eliminate the requirement of an accident by substituting the substantially broader concept of a work-related injury, it sought, inter alia, to abolish a series of complex doctrines that had required claimants to demonstrate a close association between heart…

2Cases cited4 opinions

  1. Davis v. Workmen's Compensation Appeal BoardSupreme Court of Pennsylvania · 2000
  2. Workmen's Compensation Appeal Board v. Bernard S. Pincus Co.Supreme Court of Pennsylvania · 1978
  3. Erie Bolt Corporation v. WORKERS'COMPENSATION APPEAL BOARD (ELDERKIN)Supreme Court of Pennsylvania · 2000
  4. Erie Bolt Corp. v. Workers' Compensation Appeal BoardCommonwealth Court of Pennsylvania · 2001

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