Hastings Indus. v. WCAB (Hyatt)

In Hastings Indus. v. Workmen's Compensation Appeal Board (Hyatt), 531 Pa. 186, 611 A.2d 1187 (1992) the Pennsylvania Supreme Court allowed the Board limited authority to review the amount of WCJ awards for disfigurement in order to promote uniformity in the awards throughout the state. The Supreme Court noted that evidence of the physical appearance of a claimant and the unsightliness of the disfigurement are difficult to preserve with accuracy in the record. It also observed that translation of the visual impact of a disfigurement into a monetary award involves a legal element of uniformity, and it allowed the Board to conduct its view of a claimant's visage and to modify an award where necessary to ensure that it is reasonably consistent with other similar disfigurement awards in Pennsylvania.