Claim of Smith v. Specialty Services, Inc.
Claimant, a construction foreman for Specialty Services, Inc., was injured while performing work for a church in Pennsylvania. Although Specialty filed a work-related accident report and its carrier began paying benefits, the carrier filed a notice of controversy over seven months after the Workers' Compensation Board indexed the case, exceeding the 25-day limit. The carrier argued that the late filing was due to surprise, mistake, and newly discovered evidence regarding the church's involvement, which claimant and Specialty allegedly failed to disclose. The Workers' Compensation Board refused to excuse the late filing, finding the carrier failed to demonstrate good cause. The appellate court affirmed the Board's decision, noting that the carrier had ample time to investigate and that belatedly obtained evidence is not a sufficient ground to excuse a late filing.