Injured worker cannot void Compromise and Release
Agreement with employer because of mental incompetence

(7/15/2004) -- A workers’ compensation Compromise and Release Agreement reached between an injured worker and her employer cannot be voided on the basis that the claimant was mentally incompetent to comprehend what she was agreeing to, an en banc panel of the Commonwealth Court ruled on June 9 in Stiles v. WCAB (Department. of Public Welfare). In a 5-2 decision, the majority of the panel determined that the doctrine of collateral estoppel precluded a Workers’ Compensation Judge from opening the voluntary settlement agreement. In the majority opinion written by Judge Renee L. Cohn, the panel ruled that the WCJ had already determined that “the claimant is mentally competent to comprehend the legal ramifications of entering into the agreement.” “Thus, Claimant’s mental competence was an issue actually litigated at the hearing before WCJ Desimone” and her mental competence was essential to the judgment approving the C&R Agreement material to the adjudication that did so,” Cohn wrote. “Therefore, collateral estoppel does preclude re-lititgation of this question.

A dissenting opinion by Judge Friedman who was joined by Judge Smith-Ribner said that the majority’s ruling unjustly forecloses relief to any claimant on the basis of mental impairment.