How Legal Research and Legislative History Led to a Landmark Victory: The Story Behind Steets v. Workers’ Compensation Appeal Board (Pa. 2025)

In this episode, Attorney Daniel J. Siegel takes listeners behind the scenes of his landmark victory before the Pennsylvania Supreme Court in Steets v. Workers’ Compensation Appeal Board (2025) — a decision that reshaped how Pennsylvania courts interpret key provisions of the Workers’ Compensation Act.

What began as a seemingly routine case evolved into a deep dive into the legislative intent, historical context, and statutory interpretation of a decades-old provision. Dan explains how meticulous legal research, analysis of legislative history, and strategic appellate advocacy convinced the Court to clarify — and ultimately correct — long-standing misunderstandings in the law.

Listeners will gain insight into:

• How thorough research and historical context can transform a case.
• The methods used to trace legislative history and statutory evolution in Pennsylvania.
• How appellate strategy and clear legal writing can turn complex statutory issues into compelling arguments.
• The broader impact of the Steets decision on injured workers, employers, and practitioners across the Commonwealth.

Part legal analysis, part storytelling, and part lesson in the art of advocacy, this episode illustrates how research-driven lawyering can make new law — and why attention to detail remains one of the most powerful tools in any lawyer’s arsenal.

Transcript

00;00;00;00 - 00;00;38;20

Hello! Welcome to the Legal Tech Podcast presented by Daniel J. Siegel and the Law Offices of Daniel J. Siegel and Integrated Technology Services, LLC. I'm going to bring you today on a tour of how to win an appellate case, taking you through the back stages of what we did to win this case. After years and years of bad case law before that, and we're able to take the case from one that had lost in the appellate court previously and took it to the Supreme Court and won.

00;00;38;22 - 00;01;10;15

It wasn't a one stage effort. It wasn't an easy effort. It was a group effort of many people, at its core. This is a worker's compensation case, which means it's an administrative case and decided by a worker's compensation judge. And from there, it gets appealed to what is known as the Worker's Compensation Appeal Board in Pennsylvania. From there, you can appeal as of right to the Commonwealth Court of Pennsylvania.

00;01;10;17 - 00;01;38;28

And ultimately, you can ask the Supreme Court of Pennsylvania to decide the case as well. Very few cases are decided by the Pennsylvania Supreme Court. And as a result, the Commonwealth Court is often the last court that makes any determination on workers compensation cases and many other cases involving governmental agencies. But we were able to get it to the Supreme Court and go from there.

00;01;39;00 - 00;02;12;02

So let me take you through a little bit of the history and what we did and how, as a practical matter, we never stopped searching. We kept looking for, areas to win this case, to find the angle that would finally show that Christina Steets, who was decimated by an injury and a fireworks store when the fireworks blew up in front of her and was capacity incapacitated for life and eventually died as a result of her injuries.

00;02;12;04 - 00;02;42;18

What we were trying to do, and I worked on this case, the trial level, the worker's compensation judge level. Part of the case was handled by Jerry Strubintger, a fine lawyer in northern Pennsylvania who took this case and wanted to get the right compensation for this tragically injured or worker. And he did everything he could. But as you may now, he has to follow precedent and the judges have to follow precedent.

00;02;42;25 - 00;03;15;29

And there was a case called the Estate of Harris that said if you were injured as a result of a work injury and ultimately lost parts of your body, as Christina Steets did in this terrible accident, you couldn't collect for the injured parts of the body if you're cause of the injury, and your cause of death or the work related condition you could collect if you were fortunate enough to, died from cancer or some other cause.

00;03;16;05 - 00;03;44;11

But you didn't get the same results. And that meant hundreds of thousands of dollars to her estate that she couldn't collect. So Jerry tried the case, and ultimately, it went up to the appeal board. And as a result, they affirmed. So let me talk about what happened when Jerry hired me to handle the appeal. I realized that this was a tragic case.

00;03;44;13 - 00;04;13;24

And although he had handled it exceptionally, the courts were bound by, precedent to apply future cases to the precedent of a state of Harris. Estate of Harris was the case that held that you couldn't, recover in this set of facts. And it didn't seem fair. And it didn't seem appropriate. So we then looked at the case knowing that we had a hard road to go.

00;04;13;27 - 00;04;57;17

So the first thing we did was when we looked at the case, we filed our brief and we did what is called statutory construction. Courts have to interpret statutes according to their plain meaning and have to apply them in an inconsistent manner with other cases. And we argued that the Estate of Harris case was in fact, a very unfair case and led to a result that penalized the most seriously injured workers and provides greater benefits to workers who die from non-related, non-work related causes than those whose injuries ultimately caused their death.

00;04;57;19 - 00;05;32;28

And as a result, we argued that to the Commonwealth Court, as we were arguing the case or before, really we argued the case. We had filed our brief and we're looking at it, but it kept bothering me, and I kept looking at it that as a result of that, it just didn't seem fair. And we had to know more and more about what was going on at the time of the decision, in Estate of Harris, which was many years ago.

00;05;33;00 - 00;06;07;17

And so what did I do? I went back and first looked again at the original Worker's Compensation Act, which didn't have the provision in it that barred or supposedly barred Christina Steets, from recovering for those specific losses, those many body parts that she couldn't use because of this terrible accident. So we looked at the provisions of the Workers Compensation Act as it was enacted in 1921.

00;06;07;19 - 00;06;45;02

Then we looked at something more important when this was changed, and it was changed. The act was changed in 1972. And I said, well, if it was changed in 1972, usually the legislature is changing an act because of some thing that's happening, some pressure from some party or another two cases because they bring their clauses to the legislature, because the legislature has to amend the Workers Compensation Act.

00;06;45;05 - 00;07;19;03

And lo and behold, we found those cases. There was a case called Kujawa versus Latrobe Brewing Company in 1972. And they said that unfortunately, the husband had worked for an employer, a brewing company. He suffered a disabling injury for which he received worker's compensation. But the trial court dismissed his claim because he couldn't file what's called a fatal claim petition because it was beyond the 300 weeks.

00;07;19;05 - 00;07;53;28

And because of that, he also couldn't, get the specific loss type benefits that Kristina Steets had couldn't receive either. So we looked at that case. We also looked at another case called Swerdon versus Lycoming Construction Company. And again, the result was this draconian, result because in fact, those two cases precluded injuries. If you died from a non-work related cause.

00;07;54;00 - 00;08;25;28

So at the time, you could only get benefits if you had died from a work related cause. So the legislature, to correct this inequity and this horrible unfairness, passed a bill that enabled people who died from a non-work related cause to collect specific loss benefits as well as worker's comp benefits. And there are different kinds of benefits. It's a little confusing, but you can look at it this way.

00;08;26;01 - 00;08;55;01

You collect worker's compensation benefits, wage lost benefits when you're unable to work when you die. However, after that, obviously you can't be unable to work because you're unable to do anything tragically. But in that those cases it's after B the worker's comp wage losses stop that you can receive, specific loss benefits. And that's the way the Worker's Comp Act had always been, whether you lived or died.

00;08;55;04 - 00;09;25;05

Well, the court, when it got to Estate of Harris, decided that the legislature had amended the law so that now you could only get benefits if you had died from the non-work related cause. And that was the title that, people put on the section of the act that was amended. The only problem is the titles don't mean anything in the Statutory Construction Act says that.

00;09;25;07 - 00;10;09;01

And as a result, we argued that's not an appropriate statutory measure. And we did that in order to show that it was unfair to Christina states and all those people who for decades had been denied benefits because a state of Harris, we believed, had been erroneously decided and a state of Harris, was in 2004. So from 2004 to roughly 20 years later, all those people who died from a work related cause couldn't collect post posthumous.

00;10;09;04 - 00;10;48;15

Specific loss benefits. So we argued that to the Commonwealth Court and unfortunately, the court in a 5 to 2 decision agreed with the prior decision in Harris. They basically held that Harris had been the law and there was no intervening factor that warranted deciding it differently. Fortunately, we were able to convince two judges, just Judge Ellen Ceisler and President Judge Renee Cohn Jubilerer, that this was unfair.

00;10;48;18 - 00;11;23;03

And they filed a dissent. So it was a 5 to 2 ruling, and they agreed. They said the there was nothing that suggested an intent to, punish, people who died from a work related cause. And they also made other arguments as well. And they should they felt she should have been granted benefits, as we argued. But at that point we had lost the case and it was a 5 to 2 decision.

00;11;23;06 - 00;11;53;17

And it became final. Except that in Pennsylvania you are permitted to ask the Supreme Court for allocatur, which means you're asking the Supreme Court to hear the case. They don't have to hear the case. They hear only a small percentage of the cases. Fortunately, I have a very good track record with framing the issues and making those arguments to the Supreme Court.

00;11;53;19 - 00;12;33;24

I'll be arguing five different appeals in November of this year, 2025. For example, all cases on which I was framing the issues or had a major hand in framing the issues. The case was then brought to the Pennsylvania Supreme Court. They agreed to hear our case, and what the issue was was very simple. Did the legislature intend only to award posthumous, specific loss benefits if you died from a non-work related cause and preclude benefits if you died from a work related cause?

00;12;33;26 - 00;13;03;14

Fortunately, the Supreme Court agreed with us. The Supreme Court looked at the circumstances, of that of our case. It looked at Harris. It looked at a variety of other cases and decided that, no, that is not the effect of the act that the legislature intended. It is not in fact, what any, reasonable person would have expected.

00;13;03;18 - 00;13;34;04

And as a result, the Supreme Court reversed the Commonwealth Court and awarded benefits to Christina Steets’ heirs. And as a result, they were, given the benefits and have been made whole in terms of the money they were owed. We'll never be able to bring Christina state steeds back to life. We'll never be able to give her the life that she had.

00;13;34;08 - 00;14;11;13

That was ruined. And essentially, taken away from her. The minute those fireworks, die out or exploded. But because, unfortunately, the only measure we have is benefits. And in workers compensation, it's important to note that unfortunately, we don't. The give the injured worker any pain and suffering. You hear about all these large verdicts, but the large verdicts don't occur in, workers compensation where the worker, the only avenue to sue is the employer.

00;14;11;16 - 00;14;41;27

The employer, called the Great Bargain, gives away and agrees to pay workers comp benefits in exchange for the employee giving up his or her right to sue. So we have a limited amount of benefits that are here. No pain and suffering, but fortunately, because we weren't going to stop and listen to the courts, including the Commonwealth courts, say you're bound by Estate of Harris.

00;14;42;03 - 00;15;15;14

You're stuck with that. That's what they call stare decisis, and you're out of luck. I don't believe for a minute, in most cases, that you ever, accept what the Commonwealth Court or the Superior Court or intermediate courts say as the final arbiter. There's always a chance that the Supreme Court will, in fact, take a case and reverse and give your party in this case, the claimant, the injured worker justice.

00;15;15;16 - 00;15;44;17

And that's what happened here. The court agreed. And as a result, we were able to prove, in, very clear fashion that the intent of the law was to award specific loss benefits, whether the person died from the work injury or not, from work, and, excuse me, not from the work injury court or a work related cause or a non-work related cause.

00;15;44;22 - 00;16;12;00

It didn't matter as long as they suffered the injury. And at that point they were entitled to the benefits if they were received at that point. So that's the example here of how we turned a case that looked to be a loser because the Supreme Court had been ruling, the Commonwealth Court had been ruling against us for many years, but we didn't give up.

00;16;12;02 - 00;16;44;02

And, 21 years later, on May 2025, we were able to provide justice to the estate and give her or give her heirs at least what we could. We'll never bring her back to life. When we handle worker's compensation cases. We recognize no money is going to ever, fix whatever is injured. No one is ever going to make the party whole.

00;16;44;04 - 00;17;16;26

And the because the benefits are limited, it is very important that we look at every avenue and make certain that every penny is given to the injured worker that they're entitled to. I'm Dan Siegel, I'm an appellate lawyer. I'm also a lawyer who handles worker's compensation cases every day in my office. And we are proud to represent injured workers, and fight for their rights, no matter how long it takes.

00;17;16;28 - 00;17;45;02

We will do what we have to do. This has been the legal tech podcast, sponsored by, Integrated Technology Services and the Law Offices of Daniel J. Siegel, LLC. We thank you for listening and hope that this has brought some interesting perspective to you. And you'll listen to future podcasts. Thank you.