McKenna v. Workers' Compensation Appeal Board (SSM Industries, Inc. and Liberty Mutual Insurance Co.), No. 454 C.D. 2010 (Pa. Cmwlth., August 18, 2010)
Holding: Because a Compromise and Release Agreement is not binding until it is approved by a Workers' Compensation Judge, an employer may refuse to proceed with a C&R hearing if negotiations break down. In this case, the employer refused to proceed with a C&R unless the claimant signed an agreement stating that he would resign from and not seek re-employment with the defendant employer.