reasoned decision requirement (Pennsylvania) · Go Syfert
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reasoned decision requirement in Pennsylvania

60 Pennsylvania opinions name it 2 courts 2000–2025 23 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (17)

CaseFollowedCited
Amandeo v. Workers' Compensation Appeal Boardgreen
pacommwct · 2012 · cited in 19 Pennsylvania opinions naming this issue, 2016–2025
2 sentences

2025The WCJ had two opportunities to assess Claimant’s demeanor and found him credible, and “a WCJ’s observation of a witness’s demeanor alone is sufficient to satisfy the reasoned decision requirement.” Amandeo, 37 A.3d at 77 .

2024This requirement is satisfied if the WCJ summarizes the witnesses’ testimony “and adequately explain[s] his credibility determinations.” Clear Channel Broadcasting v. Workers’ Compensation Appeal Board (Perry), 938 A.2d 1150, 1157 (Pa. Cmwlth. 2007). “[W]hile summaries of testimony alone would be insufficient to satisfy the reasoned decision requirement, where a WCJ summarizes testimony and also objectively explains his credibility determinations, the decision will satisfy the requirement.” Amandeo v. Workers’ Compensation Appeal Board (Conagra Foods), 37 A.3d 72, 76 (Pa. Cmwlth. 2012).

1619
Clear Channel Broadcasting v. Workers' Compensation Appeal Boardgreen
pacommwct · 2007 · cited in 13 Pennsylvania opinions naming this issue, 2012–2025
2 sentences

2025Appeal Bd. (Perry), 938 A.2d 1150, 1157 (Pa. Cmwlth. 2007). “[W]hile summaries of testimony alone would be insufficient to satisfy the reasoned decision requirement, where a WCJ summarizes testimony and also objectively explains his credibility determinations, the decision will satisfy the requirement.” Amandeo v. Workers’ Comp.

2024This requirement is satisfied if the WCJ summarizes the witnesses’ testimony “and adequately explain[s] his credibility determinations.” Clear Channel Broadcasting v. Workers’ Compensation Appeal Board (Perry), 938 A.2d 1150, 1157 (Pa. Cmwlth. 2007). “[W]hile summaries of testimony alone would be insufficient to satisfy the reasoned decision requirement, where a WCJ summarizes testimony and also objectively explains his credibility determinations, the decision will satisfy the requirement.” Amandeo v. Workers’ Compensation Appeal Board (Conagra Foods), 37 A.3d 72, 76 (Pa. Cmwlth. 2012).

1313
Daniels v. Workers' Compensation Appeal Boardgreen
pa · 2003 · cited in 18 Pennsylvania opinions naming this issue, 2004–2024
2 sentences

2024This Court has explained: While many cases since Daniels [v. Workers’ Compensation Appeal Board (Tristate Transport), 828 A.2d 1043 (Pa. 2003),] have addressed the adequacy of the reasons set out by the WCJ in support of his or her credibility determination, we have not clearly addressed the standard by which we review such reasoning. 4 While many petitioners challenging an adverse credibility determination would suggest that we review each and every component of the WCJ’s reasoning for substantial evidence and reverse or remand if we can find any flaw, we do not believe the reasoned decision

2023Appeal Bd. (Tristate Transp.), . . . 828 A.2d 1043, 1052 ([Pa.] 2003). “[W]hile summaries of testimony alone would be insufficient to satisfy the reasoned decision requirement, where a WCJ summarizes testimony and also objectively explains [the WCJ’s] credibility determinations, the decision will satisfy the requirement.” Amandeo v. Workers’ Comp.

818
Dorsey v. Workers' Compensation Appeal Boardgreen
pacommwct · 2006 · cited in 8 Pennsylvania opinions naming this issue, 2014–2022
2 sentences

2022Moreover, to comply with section 422(a) of the Act, a WCJ’s decision must permit adequate appellate review because the purpose of the reasoned decision requirement “is to spare the reviewing court from having to imagine why the WCJ believed one witness over another.” Dorsey v. Workers’ Compensation Appeal Board (Crossing Construction Co.), 893 A.2d 191, 194-96 (Pa. Cmwlth. 2006).

2022In conducting a reasoned decision analysis, we note that “[s]ection 422(a) does not permit a party to challenge or second-guess the WCJ’s reasons for credibility determinations,” Dorsey, 893 A.2d at 195 , and, as the factfinder and sole arbiter of credibility, “the WCJ may reject the testimony of any witness in whole or in part, even if that testimony is uncontradicted.” Serrano v. Workers’ Compensation Appeal Board (Chain Bike Corp.), 718 A.2d 885, 889 (Pa. Cmwlth. 1998).

58
Green v. Workers' Compensation Appeal Board (US Airways)green
pacommwct · 2017 · cited in 3 Pennsylvania opinions naming this issue, 2017–2019
2 sentences

2019Rather, to meet the reasoned decision requirement, “a WCJ must only make findings necessary to resolve the issues raised by the evidence and relevant to the decision.” Id. at 148 .

2018However, “[i]n making these arguments, Claimant misconstrues the reasoned decision requirement of the Act.” Green v. Workers’ Compensation Appeal Board (US Airways), 155 A.3d 140, 147 (Pa. Cmwlth.), appeal denied, 169 A.3d 1081 (Pa. 2017).

13
PPL v. Workers' Compensation Appeal Boardgreen
pacommwct · 2010 · cited in 2 Pennsylvania opinions naming this issue, 2020–2020
2 sentences

2020PPL, 5 A.3d at 845 .

2020See PPL 14 v. Workers' Compensation Appeal Board (Rebo), 5 A.3d 839, 445 (Pa. Cmwlth. 2010).

12
Gabriel v. Workmen's Compensation Appeal Boardgreen
pacommwct · 1986 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Appeal Bd. (No. 1 Contracting Corp.), 518 A.2d 895, n.1 (Pa. Cmwlth. 1986) (stating that “[a] recitation of the testimony of a witness does not constitute a finding of fact.”).

11
Serrano v. Workers' Compensation Appeal Boardgreen
pacommwct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Serrano v. Workers’ Compensation Appeal Board (Ametek, Inc.), 154 A.3d 445, 453 (Pa. Cmwlth. 2017).

11
Republic Steel Corp. v. Workmen's Compensation Appeal Boardgreen
pa · 1980 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022Appeal Bd. (Shinsky), 421 A.2d 1060, 1063 (Pa. 1980). 9 Since we hold that the first issue is dispositive in this case, there is no need to reach the questions regarding the suspension of benefits or the reasoned decision standard.

11
Serrano v. Workers' Compensation Appeal Boardgreen
pacommwct · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022In conducting a reasoned decision analysis, we note that “[s]ection 422(a) does not permit a party to challenge or second-guess the WCJ’s reasons for credibility determinations,” Dorsey, 893 A.2d at 195 , and, as the factfinder and sole arbiter of credibility, “the WCJ may reject the testimony of any witness in whole or in part, even if that testimony is uncontradicted.” Serrano v. Workers’ Compensation Appeal Board (Chain Bike Corp.), 718 A.2d 885, 889 (Pa. Cmwlth. 1998).

11
A & J Builders, Inc. v. Workers' Compensation Appeal Boardgreen
pacommwct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Appeal Bd. (Verdi), 78 A.3d 1233, 1243 (Pa. Cmwlth. 2013).

11
Casne v. Workers' Compensation Appeal Boardgreen
pacommwct · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018Appeal Bd. (Stat Couriers, Inc.), 962 A.2d 14, 18 (Pa. Cmwlth. 2008).

11
Acme Markets, Inc. v. Workers' Compensation Appeal Boardgreen
pacommwct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016The reasoned decision requirement does not, however, require a WCJ to: “discuss all the evidence presented,” Dorsey v. Workers’ Compensation Appeal Board (Crossing Construction Company), 893 A.2d 191 , 194 n.4 (Pa. Cmwlth. 2006); “give a line- by-line analysis of each statement by each witness, explaining how a particular statement affected the ultimate decision,” Acme Markets, Inc. v. Workers’ Compensation Appeal Board (Brown), 890 A.2d 21, 26 (Pa. Cmwlth. 2006); or “set forth in detail the process by which he arrived at such a determination,” CPV Manufacturing, Inc. v. Workers’ Compensation

11
CPV Manufacturing, Inc. v. Workers' Compensation Appeal Boardgreen
pacommwct · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016The reasoned decision requirement does not, however, require a WCJ to: “discuss all the evidence presented,” Dorsey v. Workers’ Compensation Appeal Board (Crossing Construction Company), 893 A.2d 191 , 194 n.4 (Pa. Cmwlth. 2006); “give a line- by-line analysis of each statement by each witness, explaining how a particular statement affected the ultimate decision,” Acme Markets, Inc. v. Workers’ Compensation Appeal Board (Brown), 890 A.2d 21, 26 (Pa. Cmwlth. 2006); or “set forth in detail the process by which he arrived at such a determination,” CPV Manufacturing, Inc. v. Workers’ Compensation

11
Leon E. Wintermyer, Inc. v. Workers' Compensation Appeal Boardgreen
pa · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2003–2003
2 sentences

2003When Wintermyer corrected this void, as a matter of jurisprudence, see id. at 487 , it also ensured that our interpretation of the review standard in Section 704 became harmonious with the Act’s reasoned decision requirement.

2003When Wintermyer corrected this void, as a matter of jurisprudence, see id. at 487 , it also ensured that our interpretation of the review standard in Section 704 became harmonious with the Act's reasoned decision requirement.

11
Cooper Power Systems v. Workers' Compensation Appeal Boardgreen
pacommwct · 1998 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000Hahnemann. [5] Employer disagrees and contends that the WCJ's credibility determinations here fully satisfied the reasoned decision requirement, citing Cooper Power Systems v. Workers' Compensation Appeal Board (McFarland), 722 A.2d 746 (Pa.Cmwlth. 1998), for the proposition that "a finding of one party's evidence on a particular issue to be credible is a sufficient reason for rejecting an opposing party's contrary evidence on that particular issue." (Employer's supplemental brief at 5.) However, I disagree with Employer's interpretation of Cooper Power.

2000Employer disagrees and contends that the WCJ’s credibility determinations here fully satisfied the reasoned decision requirement, citing Cooper Power Systems v. Workers’ Compensation Appeal Board (McFarland), 722 A.2d 746 (Pa.Cmwlth.1998), for the proposition that "a finding of one party's evidence on a particular issue to be credible is a sufficient reason for rejecting an opposing party’s contrary evidence on that particular issue.” (Employer's supplemental brief at 5.) However, I disagree with Employer’s interpretation of Cooper Power.

11
Greenwich Collieries v. Workmen's Compensation Appeal Boardgreen
pacommwct · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2000–2000
2 sentences

2000See e.g., Greenwich Collieries v. Workmen's Compensation Appeal Board *309 (Buck), 664 A.2d 703 (Pa.Cmwlth.1995); Sherrod v. Workmen's Compensation Appeal Board (Thoroughgood, Inc.), 666 A.2d 383 (Pa.Cmwlth.1995).

2000See e.g., Greenwich Collieries v. Workmen’s Compensation Appeal Board (Buck), 664 A.2d 703 (Pa.Cmwlth.1995); Sherrod v. Workmen’s Compensation Appeal Board (Thoroughgood, Inc.), 666 A.2d 383 (Pa.Cmwlth.1995).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Leon E. Wintermyer, Inc. v. Workers' Compensation Appeal Boardgreen
pa · 2002 · cited in 1 Pennsylvania opinions naming this issue, 2003–2003
2 sentences

2003When Wintermyer corrected this void, as a matter of jurisprudence, see id. at 487 , it also ensured that our interpretation of the review standard in Section 704 became harmonious with the Act’s reasoned decision requirement.

2003When Wintermyer corrected this void, as a matter of jurisprudence, see id. at 487 , it also ensured that our interpretation of the review standard in Section 704 became harmonious with the Act's reasoned decision requirement.

11

Also cited on this issue (12)

CaseCitedYears
PEC Contracting Engineers v. Workers' Compensation Appeal Board green
pacommwct · 1998
2 sentences

2021Moreover, in addressing a reasoned decision challenge to the WCJ’s findings, our scope of review remains limited to determining whether constitutional rights were violated, whether an error of law was committed, or whether the WCJ’s findings are supported by substantial evidence. 717 A.2d at 1089 .

2019Moreover, in addressing a reasoned decision challenge to the WCJ’s findings, our scope of review remains limited to determining whether constitutional rights were violated, whether an error of law was committed, or whether the WCJ’s findings are supported by substantial evidence. 717 A.2d at 1089 .

52017–2024
Burch v. Pennsylvania Bd. of Probation and Parole neutral
pa · 2008
2 sentences

2021Appeal Bd. (Perry), 938 A.2d 1150, 1157 (Pa. Cmwlth. 2007), appeal denied, 951 A.2d 1167 (Pa. 2008).

2021Appeal Bd. (Perry), 938 A.2d 1150, 1157 (Pa. Cmwlth. 2007), appeal denied, 951 A.2d 1167 (Pa. 2008).

32020–2021
Green v. Workers' Compensation Appeal Board green
pacommwct · 2011
2 sentences

2016“The reasoned decision requirement is simply that the WCJ must articulate some objective reasoning to facilitate appellate review of the same.” Green, 28 A.3d at 940 .

2014“The reasoned decision requirement is simply that the WCJ must articulate some objective reasoning to facilitate appellate review of the same.” Green, 28 A.3d at 940 .

22014–2016
ICT Group v. Workers' Compensation Appeal Board green
pacommwct · 2010
1 sentence

2024We addressed the reasoned decision requirement as it applies to a WCJ’s description of a work-related injury in ICT Group v. Workers’ Compensation Appeal Board (Churchray-Woytunick), 995 A.2d 927 (Pa. Cmwlth. 2010).

12024–2024
Michel v. Workers' Compensation Appeal Board green
pacommwct · 2009
1 sentence

2023“The reasoned decision requirement has been interpreted to mean that, when a WCJ reviews deposition testimony, the WCJ must state an ‘actual objective basis’ for the credibility determination.” Michel v. Workers’ Compensation Appeal Board (U.S. Steel Corp.), 966 A.2d 643 (Pa. Cmwlth. 2009).

12023–2023
Commonwealth v. Wright neutral
pa · 2017
1 sentence

2018However, “[i]n making these arguments, Claimant misconstrues the reasoned decision requirement of the Act.” Green v. Workers’ Compensation Appeal Board (US Airways), 155 A.3d 140, 147 (Pa. Cmwlth.), appeal denied, 169 A.3d 1081 (Pa. 2017).

12018–2018
Anderson v. Workers' Compensation Appeal Board green
pacommwct · 2010
1 sentence

2018Anderson v. Workers’ Compensation Appeal Board (Penn Center for Rehab), 15 A.3d 944 , 947 n.1 (Pa. Cmwlth. 2010). 9 of the reasoned decision requirement of section 422(a) of the Act, a great deal of his assertions attack the WCJ’s credibility determinations.

12018–2018
Bufford v. Workers' Compensation Appeal Board green
pa · 2010
2 sentences

2016(FOF ¶ 8(a)-(e).) We conclude that, because the WCJ provided the above objective reasons for rejecting the portions of Dr. Krum’s and Dr. Stepanuk’s opinions that conflicted with the opinions of Dr. Fras, the reasoned decision requirement of Section 422(a) of the Act is plainly satisfied. 17 Finally, Claimant contends that the WCJ erred by denying Claimant’s Reinstatement Petition because the WCJ employed a legal standard that is inconsistent with the standards set forth by our Supreme Court’s decision in Bufford v. Workers’ Compensation Appeal Board (North American Telecom), 2 A.3d 548 (Pa. 2

2016(FOF ¶ 8(a)-(e).) We conclude that, because the WCJ provided the above objective reasons for rejecting the portions of Dr. Krum’s and Dr. Stepanuk’s opinions that conflicted with the opinions of Dr. Fras, the reasoned decision requirement of Section 422(a) of the Act is plainly satisfied. 17 Finally, Claimant contends that the WCJ erred by denying Claimant’s Reinstatement Petition because the WCJ employed a legal standard that is inconsistent with the standards set forth by our Supreme Court’s decision in Bufford v. Workers’ Compensation Appeal Board (North American Telecom), 2 A.3d 548 (Pa. 2

12016–2016
Phoenixville Hospital v. Workers' Compensation Appeal Board green
pa · 2013
1 sentence

2016Id. at 843 . 5 The reasoned-decision requirement provides that a WCJ shall file a “reasoned decision, containing findings of fact and conclusions of law based upon the evidence as a whole which clearly and concisely states and explains the rationale for the decisions so that all can determine why and how a particular result was reached.” Section 422(a) of the Act.6 A WCJ need not, however, specifically evaluate every line of testimony offered to render a reasoned decision as long as he makes the crucial findings and gives reasons for his decision.

12016–2016
Daniels v. Workers' Compensation Appeal Board green
pacommwct · 2000
2 sentences

2003The dissent also acknowledged Employer’s argument that the fact that the WCJ had listed her findings and pointed to “telling portions of the record,” made it “not hard to imagine how the WCJ reached her conclusions.” But, the dissent noted that this argument merely illustrated the dissent’s point: “the 1996 amendments have cleared any doubt as to the legislature’s intent to prevent the parties from having to ‘imagine’ why certain credibility determinations were made.” Id. at 308 .

2003The dissent also acknowledged Employer's argument that the fact that the WCJ had listed her findings and pointed to "telling portions of the record," made it "not hard to imagine how the WCJ reached her conclusions." But, the dissent noted that this argument merely illustrated the dissent's point: "the 1996 amendments have cleared any doubt as to the legislature's intent to prevent the parties from having to `imagine' why certain credibility determinations were made." Id. at 308 .

12003–2003
Roth v. Workmen's Compensation Appeal Board green
pacommwct · 1989
2 sentences

2000Thus, through its enactment of the 1996 amendments, the legislature has expressed its dissatisfaction, both with accepted practice prior to the reasoned decision requirement, see e.g., Roth v. Workmen’s Compensation Appeal Board (Armstrong World Industries), 128 Pa.Cmwlth. 1 , 562 A.2d 950 (1989), and with the judicial interpretation of the 1993 reasoned decision provision, which left the WCJ’s decision-writing responsibilities largely unaffected.

2000Thus, through its enactment of the 1996 amendments, the legislature has expressed its dissatisfaction, both with accepted practice prior to the reasoned decision requirement, see e.g., Roth v. Workmen’s Compensation Appeal Board (Armstrong World Industries), 128 Pa.Cmwlth. 1 , 562 A.2d 950 (1989), and with the judicial interpretation of the 1993 reasoned decision provision, which left the WCJ’s decision-writing responsibilities largely unaffected.

12000–2000
Sherrod v. Workmen's Compensation Appeal Board green
pacommwct · 1995
2 sentences

2000See e.g., Greenwich Collieries v. Workmen's Compensation Appeal Board *309 (Buck), 664 A.2d 703 (Pa.Cmwlth.1995); Sherrod v. Workmen's Compensation Appeal Board (Thoroughgood, Inc.), 666 A.2d 383 (Pa.Cmwlth.1995).

2000See e.g., Greenwich Collieries v. Workmen’s Compensation Appeal Board (Buck), 664 A.2d 703 (Pa.Cmwlth.1995); Sherrod v. Workmen’s Compensation Appeal Board (Thoroughgood, Inc.), 666 A.2d 383 (Pa.Cmwlth.1995).

12000–2000

Where else courts name it

PA 60 (2000–2025) NM 2 (2008–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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