PA appellate court affirms trial court, upholds exclusive remedy provisions of Workers’ Compensation Act by beneficiary even though plaintiff did not qualify for any benefits under Workers’ Compensation Act.

Transportation companies are often confronted with workers’ compensation issues due to unfortunate events resulting in death or serious injury to their employees. In the course of his employment, David Macleary suffered fatal injuries and died after the brakes on his dump truck failed and the truck began to roll. The Pennsylvania Workers’ Compensation Act limits direct beneficiaries to parties such as spouses, children of a certain age, etc. The plaintiff, the adult daughter of the decedent, argued that, since she did not fall into a category of potential beneficiaries, even though Macleary received workers’ compensation benefits on the date of this death, she was not excluded from asserting a wrongful death claim. The trial court dismissed her claim, and the Superior Court upheld the ruling, prominently citing that the plaintiff, as the adult daughter of the decedent, was clearly within the class of people that the Act intended to bar from making a claim outside of the Workers’ Compensation Act, that she was not entitled to benefits was immaterial.

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