Six L's Packing Co. v. WCAB (majority)
Annotate this CaseThe issue before the Supreme Court in this case centered on whether Appellant Six L's Packing Company and its claims administrator Broadspire Services, Inc. bore liability for workers' compensation benefits as a statutory employer of an injured truck driver employed as an independent contractor. Appellant owns and leases various farms and distribution and processing facilities in North America. Claimant suffered injuries in a vehicle accident on a Pennsylvania roadway while transporting Appellant’s tomatoes between a warehouse in Pennsylvania and a processing facility in Maryland. Appellant submitted evidence to establish that it did not own trucks or employ drivers, but, rather, utilized independent contractors to supply transportation services. Appellant thus took the position that it was not Claimant’s employer. The WCJ found Appellant liable for payment of workers' compensation benefits. On further appeal, the Commonwealth Court affirmed on essentially the same reasoning as that of the WCJ. In its review, the Supreme Court affirmed the Commonwealth Court, recognizing "a degree of ambiguity inherent in the overall scheme for statutory employer liability, arising out of differences in the definitions for “contractor” as used in various provisions of the Workers' Compensation Act (WCA); the idiosyncratic conception of subcontracting fashioned in Section 302(a) [of the Act]; the substantial overlap between Sections 302(a) and (b); and the apparent differences in the depiction of the concept of statutory employment as between the Act’s liability and immunity provisions. Viewing the statutory scheme as a whole, however, and employing the principle of liberal construction in furtherance of the Act’s remedial purposes, [the Court found] it to be plain enough that the Legislature meant to require persons (including entities) contracting with others to perform work which is a regular or recurrent part of their businesses to assure that the employees of those others are covered by workers’ compensation insurance, on pain of assuming secondary liability for benefits payment upon a default."
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