Estate Entitlement to Pending Specific‐Loss Benefits Under Section 410

Introduction

This case arises from the appeal in Steets, K., Aplt. v. Celebration Fireworks, Inc. (Workers’ Compensation Appeal Board), decided May 30, 2025 by the Supreme Court of Pennsylvania. Kristina Steets, a claimant receiving workers’ compensation, had been awarded both total disability benefits and a pending award of 840 weeks of “specific‐loss” benefits for permanent impairments. While her employer appealed the specific‐loss award, Steets died of causes related to her injury. The sole issue before the Court was whether Steets’ estate (in the absence of any qualifying dependents) may collect the unpaid, future‐scheduled specific‐loss installments under Section 410 of the Workers’ Compensation Act (“the Act”).

Summary of the Judgment

The majority held that Section 410—which provides that if a claimant dies before final adjudication, “the amount of compensation due such claimant to the date of death shall be paid to the dependents … or, if there be no dependents, then to the estate”—creates an independent basis for the estate to recover the uncollected specific‐loss benefits. Relying on the plain text and the remedial purpose of Section 410, the Court concluded that “compensation due” encompasses all benefits awarded but unpaid at death, even if their scheduled commencement (after total disability) lay in the future. Consequently, the estate was entitled to the full 840 weeks of specific‐loss benefits rather than merely funeral expenses.

Analysis

Precedents Cited

Estate of Harris v. W.C.A.B. (845 A.2d 239 (Pa. Cmwlth. 2004)) – Held that Section 306(g) applies only when death results from non‐work causes, and dependents do not inherit the deceased’s independent right to specific‐loss payments if death is work‐related.
Burns International Security Services, Inc. v. W.C.A.B. (Crist) (469 A.2d 336 (Pa. Cmwlth. 1984)) – Reinforced that surviving dependents may recover specific‐loss benefits only when death is from causes other than the compensable injury, under Section 306(g).
Legislative history of Sections 306(g) and 307 – These provisions were amended in 1972 to allow dependents to collect pending specific‐loss installments only if the worker died of unrelated causes, and to delineate “fatal claim benefits” for work‐related deaths.

Legal Reasoning

The majority’s analysis proceeded in three stages:

Scope of Section 410: The Court read the term “compensation due such claimant to the date of death” broadly to capture all unpaid awards on record, not merely past‐due installments. The remedial aim—ensuring that estates are not left empty‐handed when an appeal is pending—supported a liberal construction.
Distinction From Sections 306(g) and 307: Whereas Section 306(g) (payments to survivors if death is from non‐injury causes) and Section 307 (fatal claim benefits) are strictly limited to enumerated dependents, Section 410’s text imposes no such restriction. The Court therefore viewed Section 410 as a standalone procedural provision permitting an estate claim even when the death is work‐related and no dependents exist.
Statutory‐Construction Canons: The majority rejected dissenting reliance on expressio unius est exclusio alterius (the inclusion of one implies the exclusion of another). It reasoned that different statutory chapters and purposes justify differing frameworks: one chapter for substantive survivor/dependent benefits, another for closing out contested claims.

Impact

This decision significantly broadens the rights of claimants’ estates in Pennsylvania workers’ compensation cases. Key consequences include:

Estates may now recover full unpaid awards—total disability, specific‐loss installments, etc.—when death occurs pending appeal, regardless of cause of death or dependency status.
The decision effectively carves out a procedural loophole, allowing estates to step into the shoes of claimants without regard to the substantive limitations on dependents’ benefits under Sections 306(g) and 307.
Future litigants will likely press for estate recovery in a variety of contested contexts, potentially increasing appellate filings and expanding employers’ exposure.

Complex Concepts Simplified

Specific‐Loss Benefits: A fixed schedule of weeks of compensation for the loss or loss of use of body parts (e.g., 335 weeks for a lost hand).
Total Disability Benefits: Ongoing weekly compensation for an injured worker unable to return to any employment.
Section 306(g): Governs survival of specific‐loss benefits when death is from unrelated causes; restricts recovery to dependents.
Section 307: Establishes “fatal claim benefits” for dependents when death is work‐related; calculates shares by relationship.
Section 410: A procedural provision requiring payment of any compensation determined due at final adjudication to dependents or, if none, to the estate.

Conclusion

The Supreme Court’s ruling in Steets v. Celebration Fireworks establishes that Section 410 independently entitles an estate to all unpaid workers’ compensation awards at the time of death, even those scheduled to begin after death. By divorcing procedural finalization rights from the substantive dependency framework of Sections 306(g) and 307, the Court has created a novel path for estate recovery. Moving forward, employers and insurers must account for this expanded exposure whenever a claimant dies before appellate resolution.