conducting an ambiguity analysis as to the meaning of "compensation" in section 314(a) and concluding that it "need not always include medical benefits"
How later courts described this case
- conducting an ambiguity analysis as to the meaning of "compensation" in section 314(a) and concluding that it "need not always include medical benefits"
- where there are at least two reasonable interpretations of statutory text, there exists an ambiguity
- "In giving effect to the words of the legislature, we should not interpret statutory words in isolation, but must read them with reference to the context in which they appear." (citation omitted)
- "In giving effect to the words of the legislature, we *956should not interpret statutory words in isolation, but must read them with reference to the context in which they appear." (citation omitted)
Written by the judges who cited it.
The opinion
Justice EAKIN,
concurring.
I agree with the Opinion Announcing the Judgment of the Court (OAJC), as I understand its holding to mean a Workers’ Compensation Judge has the discretion to suspend either wage loss benefits or medical benefits or both, pursuant to 77 P.S. § 651(a). I write separately to note this conclusion could have been more direct, in both how it was reached and how it was stated. The OAJC devotes significant time demonstrating how the term “compensation” is utilized differently throughout the Workers’ Compensation Act, which is true, but this discussion further muddles the meaning; suffice it to say, “compensation” in this context is ambiguous. Furthermore, concluding “ ‘compensation’ ... need not always include medical expenses,” OAJC, at 298 (emphasis in original), might directly answer the question presented for our review; however, it fails to answer the manifest question, “Now what?” To answer that question and bring the issue full-circle, I would reiterate and emphasize that because compensation does not always include medical expenses, a Workers’ Compensation Judge has the discretion to suspend medical benefits along with wage loss benefits for failure to attend a medical examination.