Krawchuk v. Commonwealth’s Empirical Analysis

Citation profile

6 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Claimant, a riveter, had frequent occasion to drill holes in metal, and in the course of the day, sharp, needle-pointed shavings became lodged in his hair, clothing, and eyebrows. The employer provided no place to change clothes and no facilities for removing these particles by brushes or vacuum appliances. Claimant left for home with some of these shavings still clinging to him, and when he was almost home, about 15 minutes^ after the close of working hours, a sharp steel sliver fell from his eyebrows into his eye causing severe injury. What can be done about a case like this? A clearer instance of an injury caused by the employment cannot be imagined. If it is noncompensable — and it was held here noncompensable — then something is basically wrong in the coverage formula.” (Citation omitted) Yet the [Commonwealth Court] majority’s formulation o would deny benefits here because the injury was not “sustained while the employe was actually engaged in the furtherance” of the employer’s business. (Blatt, J., dissenting, 397 A.2d at 1304 .)”

   1 later decision quote this exact passage
   e.g. Krawchuk v. Philadelphia Electric Co.

2. “Heart attacks, unlike accidents, do not just happen, they are brought about by something or a number of things which the heart is unable to tolerate. Their timing, as we have said, is altogether uncertain. It seems to me that if a workmen’s compensation claimant proves by competent medical opinion, credited by the fact-finder, that his heart attack was brought about by a thing or things arising from the course of his employment and related thereto, he has made out a case under Section 301(c) of the Pennsylvania Act regardless of where he was when the heart attack occurred. John Krawchuk’s widow proved more than this; she proved that her husband was actually engaged in the furtherance of the business and affairs of his employer when he was stricken at home.”

   1 later decision quote this exact passage
   e.g. Krawchuk v. Philadelphia Electric Co.

3. “does not say that the injury must “occur” or “be manifested” or “be consummated” in the course of employment. It merely says that it must “arise ... in the course of employment.” “Arising” connotes origin, not completion or manifestation. If for example, a strain occurs during employment hours which produces no symptoms, and claimant suffers a heart attack as a result some time after working hours, the injury is routinely held compensable. 3”

   1 later decision quote this exact passage
   e.g. Krawchuk v. Philadelphia Electric Co.