# Lane Enterprises, Inc. v. Workmen's Compensation Appeal Board

> Supreme Court of Pennsylvania · July 5, 1994 · 537 Pa. 426

URL: https://www.frixlaw.com/law-library/cases/9535000

## Case

- **Full name:** LANE ENTERPRISES, INC. and Commercial Union Insurance Company, Appellants, v. WORKMEN’S COMPENSATION APPEAL BOARD (PATTON), Appellees
- **Court:** Supreme Court of Pennsylvania
- **Decided:** July 5, 1994
- **Citations:** 537 Pa. 426; 644 A.2d 726; 1994 Pa. LEXIS 239
- **Precedential status:** Published
- **Opinion:** Concurrence by Papadakos
- **Judges:** Nix, Flaherty, Zappala, Papadakos, Cappy, Castille, Montemuro, Docket, Larsen
- **Cited by:** 18 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9535000

## How later opinions describe it (automated extraction)

- holding that an annual bonus, calculated on the basis of yearly performance, should be pro-rated over the entire year in which it was earned
- holding that an annual bonus based on yearly performance is included in wage
- applying same rule to annual bonus

## Opinion text

PAPADAKOS, Justice,
concurring.
I concur in the result reached by the majority only because Appellee’s brief admits (at page 5 thereof) that the bonus earned by the claimant in this case was, in fact, a distribution from an established profit sharing plan (although it was not, for tax reasons, so characterized) and hence earned over the course of the full previous year. We should not, however, adopt a per se rule treating all bonuses that way under the Worker’s Compensation Act. It is entirely possible that a “bonus” may be paid in some circumstances that is a one-time payment that should not be prorated over a full year’s period. A per se rule is, on that basis, inherently unfair and may unlawfully punish workers in many cases.
CAPPY, J., joins this concurring opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9535000. Public record. Not legal advice.