Bowman v. Sunoco, Inc., 620 Pa. 28

Summary

The Pennsylvania Supreme Court held that a workers’ compensation disclaimer releasing claims against an employer’s customers did not violate the public policy embodied in § 204(a) of the Pennsylvania Workers’ Compensation Act. The disclaimer applied to third-party tort claims for injuries covered by workers’ compensation and did not deprive the employee of workers’ compensation benefits. The Court also rejected challenges based on the employer’s waiver of subrogation rights and the release of claims arising after execution of the disclaimer.

Holdings

1. Section 204(a) applies to agreements barring claims against an employer and does not invalidate a release of an employee's claims against a third-party customer for injuries covered by workers' compensation.
2. An employer may voluntarily waive its statutory workers' compensation subrogation rights, and such a waiver does not violate the public policy underlying the Act.
3. The disclaimer was not invalid merely because it was executed before the negligence claim accrued where the parties specifically contemplated future work-related injury claims against Allied's customers.

Questions Presented

1. Whether Pennsylvania Workers' Compensation Act § 204(a) invalidates a preinjury release of an employee's negligence claims against a third-party customer of the employer for injuries covered by workers' compensation.
2. Whether Allied's waiver of its statutory subrogation rights under § 319 violates the public policy underlying the Workers' Compensation Act.
3. Whether the disclaimer was invalid because it released claims that had not accrued when the disclaimer was signed.

Disposition

affirmed