Workers Compensation

A Pennsylvania court ruled that a disabled worker who forfeited his workers compensation benefits when he accepted a job as a minister was not entitled to a reinstatement of his benefits.

Church Law and Tax2000-01-01

Workers Compensation

Key point 8-02. All states have enacted workers compensation laws to provide benefits to employees who are injured or become ill in the course of their employment. Benefits generally are financed through insurance premiums paid by employers. Churches are subject to workers compensation laws in most states.

A Pennsylvania court ruled that a disabled worker who forfeited his workers compensation benefits when he accepted a job as a minister was not entitled to a reinstatement of his benefits when he quit his ministerial position for reasons unrelated to his previous disability. In 1973, an individual employed by a secular company sustained a work-related back injury. He underwent surgery for that injury, which caused damages that rendered him disabled. In 1992, the individual returned to work as a minister, and his disability benefits were terminated. He was not an ordained minister but was hired to preach sermons and counsel parishioners. Having no experience in counseling, he became uncomfortable with the possibility of being sued over the advice that he gave the parishioners. He also had problems with one of the two members of the church’s board, which caused him to experience a lot of stress. Eventually, he quit his position with the church because he was unable to afford liability insurance and had problems with one of the board members, which caused him stress. He filed for a reinstatement of his disability benefits, stating that he was no longer employed due to a disability related to his original 1973 work injury. The church opposed any reinstatement of benefits, and the minister appealed. A court noted that when workers compensation claimants voluntarily quit their job, they have the burden of proving that they did so due to their disability. However, when a claimant quits a job for reasons unrelated to the disability or work-related injury, benefits are not reinstated. The court observed: “Here, claimant voluntarily left his position as a minister because of stress and interpersonal problems. The [trial judge] specifically found claimant left his job based on problems dealing with people in counseling and with a difficult trustee and a lack of liability insurance.” As a result, the minister was not entitled to have his prior benefits reinstated. The court concluded:

[We recognize] that an employee that attempts to reenter the work force is admirable. Unfortunately, the [law] requires that if such employee terminates his employment, in order to receive benefits, the termination must be based upon his inability to work because of his original work-related injury. No other reason for terminating the employment meets the claimant’s burden. The Workers’ Compensation Law requires a claimant seeking reinstatement to show that through no fault of his own his earning power was once again adversely affected by his disability. Claimant failed to do so here.

Application. Persons who are receiving workers compensation benefits because of a previous job-related injury sometimes enter the ministry, thinking they will be able to perform such a job. If they later determine that they cannot do so, they may not be able to have their previous benefits reinstated, unless they had to quit their ministerial position because of the original disability. Beattie v. Workers Compensation Appeal Board, 713 A.2d 187 (Common. Ct. Pa. 1998). Workers Compensation

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