Steets v. Celebration Fireworks, Inc.
In a significant – and complex – decision issued on May 30, 2025, the Pennsylvania Supreme Court changed the law for deceased workers who have suffered specific loss injuries. The court reversed decades-old case law that held that specific loss benefits vanish if an injured worker dies. The Court, in Steets v. Celebration Fireworks, Inc., ruled that if a worker dies from a work-related injury before getting paid their specific loss benefits, those benefits now go to their estate. That means your family – whether or not they depended on your paycheck – can get what’s owed to you, even if you die.
First of all, this case dealt with specific loss benefits, not medical or wage loss benefits. In Pennsylvania, a “specific loss” Workers’ Compensation injury refers to the permanent loss or loss of use of a body part (like a hand, foot, eye, or hearing, or serious and permanent disfigurement of the head, face, or neck).
In this case, the injured worker was – to quote the Court – “horrifically injured” in a fireworks explosion in 2017. The judge found that Ms. Steets had for all intents and purposes lost both of her arms in the accident and, accordingly, awarded 840 weeks of compensation for that specific loss. However, she was still receiving weekly wage loss, benefits. Under Pennsylvania law, these benefits are not paid until “ordinary” weekly wage loss benefits stop. Consequently, once those total disability benefits ceased, Steets would have been entitled to 840 weeks of specific loss benefits.
However, before she ever saw a penny of that award, she died from complications of the work injury. Not surprisingly, the insurer argued they didn’t have to pay anything beyond funeral costs because of how the old appellate rulings interpreted the law.
That used to be the rule in Pennsylvania. A 2004 case, Estate of Harris, said if you died from the same injury that got you the benefits, those payments didn’t carry over to your estate. But if you died from something unrelated to the injury – like a heart attack or a car crash – then your family could collect. It didn’t make sense, and it didn’t sit right with a lot of people. Including the Estate of Ms. Steets.
Thankfully, the Pennsylvania Supreme Court agreed.
They overruled Estate of Harris and said it plainly: if you were owed money for your work injury and died before it was paid, your estate should still get it, even if your death was caused by the injury.
They emphasized that the Workers’ Compensation Act is remedial legislation, intended to provide fair, no-fault compensation for injured workers. The majority underscored its humanitarian purpose: ensuring financial support continues even posthumously, rather than denying benefits due to technicalities.
Of the seven justices, Justices Wecht (R) and Brobson (D) issued dissenting (and therefore not binding) opinions that are more insurance company-friendly. The current Pennsylvania Supreme Court seems to be slowly shifting toward a more worker-friendly interpretation of the Workers’ Compensation Act. Recent decisions are seemingly emphasizing fairness and the humanitarian purpose of the law, now ensuring injured workers and their families receive compensation – even posthumously – by overruling older case law that limited benefits after a worker’s death.
This is a win for injured workers and their families. It means employers and insurance companies can’t dodge responsibility just because a worker dies before the check clears. It also puts all workers on more equal footing – no more nonsense where someone dying from a heart attack gets more than someone killed by a jobsite explosion.
If you or a loved one is dealing with a serious work injury, this ruling could affect you directly. And if you’ve been told that your benefits died with the worker, think again. It might be time to talk to a lawyer. Contact Prince Law today if you need a consultation.