PA Supreme Court rejects appeal from a former Pittsburgh Steelers

The Pennsylvania Supreme Court has denied the appeal of former Pittsburgh Steeler Ainsley Battles.  The former Steelers’ player was seeking workers’ compensation benefits for a torn hamstring, which was an on-the-field injury.

Battles had surgery on the hamstring in 2004 and underwent subsequent rehabilitation with the Steelers training staff.  Eventually he was eventually released to play football again by his doctor in August of 2005. After his medical release, in 2006 the Steelers did not resign Battles to the roster.  Subsequently, he retired from football and filed a Claim Petition for wage loss benefits in 2007.  The Claim Petition sought total disability benefits from Sept. 12, 2004 through Jan. 30, 2007, and partial benefits from Jan. 31, 2007, to the present.  He also received a $50,000 severance payment from the Steelers.

Battles claim was eventually denied by a Workers Compensation Judge based on the following.

The judge found that the Steelers had essentially accepted a medical-only claim by recognizing Battles’s work injury and pay all medical expenses associated with it.  The judge also noted that the team had paid Battles the amount of his salary owed under his one-season contract.

The Commonwealth Court upheld the WCJ and the Appeals Board.

The panel wrote that it is undisputed that Battles missed the 2004-05 season due to his hamstring injury, but it noted that Battles suffered no earnings losses during that period because the Steelers paid Battles “what he was contractually entitled to receive for the 2004-2005 season,” the memorandum stated.  The appeals judges had also stressed that the team’s decision to hire another player to replace Battles had nothing to do with Battles’s hamstring injury.“In sum, the [workers’ compensation appeals] Board did not err in denying the instant claim,” the Commonwealth Court panel had written. “[Battles] is not entitled to disability benefits because he failed to prove that his work injury caused him to experience a loss of earnings.”

The Supreme Court denied the Appeal on January 22, 2014, offering no opinion.

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