The Pennsylvania Supreme Court has declined to hear the appeal of a
former Pittsburgh Steelers player who lost his bid for workers’ compensation benefits tied to an on-the-field injury.
In a brief order issued last week, the high court denied a final appeal by Ainsley T. Battles, who had played professional football as a defensive back for the Steelers during the 2004-05 season.
Battles tore his left hamstring during the first game of the season back on Sept. 12, 2004, records show.
The player underwent surgery three days later and subsequently began a rehabilitation regimen with the team’s athletic trainer.
In early June 2005, the Steelers opted to not re-sign Battles, although it allowed him to continue rehab with team trainers at no cost.
Battles was ultimately given $50,000 in severance pay.
Battles was cleared to play professional football again in August 2005, but he was never offered a spot on any team; he retired from professional play in 2006.
Since that time, Battles has worked as a personal trainer and as a medical device salesman.
He currently teaches social studies and coaches high school football and track in Georgia, records show.
In the summer of 2007, Battles filed a claim seeking total disability benefits from Sept. 12, 2004 through Jan. 30, 2007, and partial benefits from Jan. 31, 2007, to the present, court records show.
The Steelers denied the allegations, after which the matter was assigned to a workers’ compensation judge who ultimately ruled against Battles, concluding that while Battles sustained a work-related injury, the injury did not result in any income losses.
The judge found that the Steelers had essentially accepted a medical-only claim by recognizing Battles’s work injury and pay all medical expenses associated with it.
The judge also noted that the team had paid Battles the amount of his salary owed under his one-season contract.
The workers’ compensation judge, crediting the opinions of two physicians, also found that after surgery and rehab, Battles had regained his physical ability to once again play professional football.
Battles had lost his spot on the team because his employer had acquired another, “better,” player, not because of Battles’s injury and physical condition, the administrative judge had determined.
In the end, the judge, in denying the workers’ comp claim, determined that Battles failed to prove that his injury resulted in any compensable period of disability.
The Workers’ Compensation Appeal Board sided with the administrative judge.
Battles then appealed the administrative judge’s decision to Pennsylvania’s Commonwealth Court, arguing that his hamstring injury left him without the skills necessary to play professional sports.
The appellate body, however, sided with the workers’ comp judge and the WCAB, determining that Battles failed to meet his burden of showing a compensable disability.
Battles, the three-judge Commonwealth Court panel wrote in its Aug. 29, 2013, memorandum opinion, failed to prove that his work injury resulted in a disability, in this case, a loss of earnings.
The panel wrote that it is undisputed that Battles missed the 2004-05 season due to his hamstring injury, but it noted that Battles suffered no earnings losses during that period because the Steelers paid Battles “what he was contractually entitled to receive for the 2004-2005 season,” the memorandum stated.
The appeals judges had also stressed that the team’s decision to hire another player to replace Battles had nothing to do with Battles’s hamstring injury.
The Steelers, the judges noted, would have considered re-signing Battles if the other player had signed with a different team.
“In sum, the [workers’ compensation appeals] Board did not err in denying the instant claim,” the Commonwealth Court panel had written. “[Battles] is not entitled to disability benefits because he failed to prove that his work injury caused him to experience a loss of earnings.”
In its Jan. 22 per curiam order, the Supreme Court did not offer an explanation behind its decision to deny Battles’s final appeal.