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Christian Petrucci of the Law Offices of Christian Petrucci. Christian Petrucci of the Law Offices of Christian Petrucci.

Every now and again, the Commonwealth Court reports a previously nonprecedential opinion.  These newly precedential decisions can sometimes fly under the radar, but they are worth reviewing. One such instance occurred recently in the matter of Dickerson v. Workers’ Compensation Appeals Board  (A Second Chance), 1218 C.D. 2019 (Apr. 2020), which dealt with whether a claim petition is time-barred under Section 315 of the act if it is filed more than three years after the date of injury when medical bills are paid in connection with the claim. Of course, this inquiry necessarily warranted the court revisiting the seminal case on the matter from the Pennsylvania Supreme Court in Schreffler v. Workers’ Compensation Appeals Board (Kocher Coal), 788 A.2d 963 (Pa. 2002).

Section 315, amended for clarity, states in pertinent part:

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