A Party Has to Advise the Referee of His Objections As Early As Possible

In Dehus v. Unemployment Compensation Board of Review, 118 Pa. Commw. 344, 545 A.2d 434 (Pa. Cmwlth. 1988) the Court held that where a party has an opportunity to object during the proceedings before the referee, it is incumbent upon that party to advise the referee of his objections at that time. Id. at 350, 545 A.2d at 437. In Dehus, a claimant failed to raise a due process issue before the referee, but did raise that issue before the Board. Nevertheless, this Court concluded that the claimant waived his contention by failing to raise it before the referee. Id. In Dehus this Court referred to our Supreme Court's decision in Wing v. Unemployment Compensation Board of Review, 496 Pa. 113, 436 A.2d 179 (1981) for the rule that an administrative law tribunal must be given the opportunity to correct its errors as early as possible and that the parties must be required to advance all legal theories before the tribunal to avoid a series of piecemeal adjudications.