Disability Claim Without Earnings Loss Cost Steelers Player Workers’ Comp

Worker’s compensation laws are designed to protect people who are injured on the job. But an injury on the job doesn’t always result in compensation, as shown by a recent Pennsylvania Supreme Court ruling.

The case involved NFL player Ainsley Battles, a former defensive back for the Pittsburgh Steelers. He tore his left hamstring in the first game of 2004. The team surgeon operated on him and the Steelers put him into rehab. Then, they opted not to renew Battles’ contract at the end of the season. Even though he was cleared by the team doctor as able to play, he was hired by another team and retired from professional play in 2006. He is now is a social studies teacher and coach.

Was Battles due for worker’s compensation? After all, he was injured on the job-and he no longer qualifies for that type of job.

Battles thought so, and filed a claim against the Steelers seeking benefits. When that claim was denied in Commonwealth Court, he appealed it to the highest court in the state. Unfortunately, the burden of proof would be on Battles. “In a claim petition, the claimant has the burden of proving all elements necessary to support an award of benefits,” according to court records. In other words, Battles had to prove that his injury resulted in disability, which is synonymous with the loss of earning power.

So the real question became, “Did Battles lose money because of his injury on the job?”

Here’s what led to the decision that the Steelers had ultimately fulfilled their end of the agreement-and didn’t owe him a dime in disability:

• “The Steelers accepted a medical-only claim by recognizing Battles’ work injury and paying all medical expenses associated with it,” reported the Pennsylvania Record, Pennsylvania’s Legal Journal.
• For the duration of his contract, Battles received his full salary from the Steelers.
• The Steelers paid Battles $50,000 in severance when they decided not to renew his contract.
• Battles was allowed to continue physical therapy, free of charge, after his contract was terminated.
• Battles was medically cleared to play professional football. Law360 reported, “In testimony before the WCAB, the opinion said, doctors with the Steelers testified that Battles had seen ‘superb results’ from his surgery and that the player had ‘fully recovered from a functional standpoint and was fit to play in the NFL without any restrictions.'”

The Pennsylvania Supreme Court denied the appeal on the basis that the claimant, Battles, did not prove without reasonable doubt that his injury resulted in disability, e.g. loss of earning power. In essence, he lost his spot on the team because the Steelers replaced him with a more skilled player. It might have happened even if he hadn’t gotten injured.

Worker’s compensation laws protect people injured on the job. But it is important to remember that disability claims must be backed by solid evidence of loss of earnings. The system protects both employers and employees in this way.

If you have any questions, or would like to discuss your own unique situation, contact us anytime.