Workers' Compensation - Judgments

United Parcel Service v. Hohider, 2008 PA Super 148 (July 7, 2008)

Holding: An employer may enter a judgment in the Court of Common Pleas based upon a WCJ’s Order directing payment by an employee to an employer of a liquidated sum in satisfaction of the employer’s right to subrogation. The Court notes that, although Section 428 of the Act, 77 P.S. § 921, permits only employees or dependents to enter a judgment in a court of common pleas as a result of an unpaid Order by a WCJ, precluding an employer from doing so would render the WCJ’s order a nullity. The Court based its opinion upon case law and Section 319 of the Act.