Scierka v. Department of Corrections

In Scierka v. Department of Corrections, 852 A.2d 418 (Pa. Cmwlth. 2004), the claimant applied for both workers' compensation and Act 632 benefits, alleging post traumatic stress disorder. A WCJ granted workers' compensation benefits, and the Secretary denied Act 632 benefits. Without any analysis of the principles of collateral estoppel the Court stated: Cantarella controls. The doctrine of collateral estoppel does not preclude the Department from making findings contrary to those made by a WCJ in a collateral workers' compensation proceeding. Id. at 422.