Latest Case: Sadler v. WCAB (Apl of: Phila Coca-Cola Co.) (Labor & Employment Law)

Impeaching a Former President Is Plainly Constitutional

NEIL H. BUCHANAN

UF Levin College of Law professor and economist Neil H. Buchanan argues that the text of the Constitution makes clear that Congress has the power to impeach and convict Donald Trump, even though he is no longer President. Buchanan describes the unambiguous textual support for this conclusion, which Buchanan (and others) argue is also amply supported by the Constitution’s purpose, structure, and other interpretive approaches.

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Sadler v. WCAB (Apl of: Phila Coca-Cola Co.)

Docket: 6 EAP 2020

Opinion Date: January 27, 2021

Judge: Donohue

Areas of Law: Government & Administrative Law, Labor & Employment Law

In 2012, Appellee Carl Sadler was injured while working as a production manager for Philadelphia Coca-Cola Company (“PCCC”). PCCC issued a notice of compensation payable, acknowledging Sadler’s injuries as a right pinky finger amputation and a low back sprain, and providing that Sadler was entitled to a weekly disability rate of $652 based upon an average weekly wage of $978. On August 13, 2013, Sadler was charged with a crime in New Jersey. Because he could not post bail, Sadler remained incarcerated for 525 days, until January 22, 2015, when he pled guilty. At sentencing, immediately after accepting Sadler’s plea, the trial court sentenced him to 525 days of incarceration, gave him credit for time served, and immediately released him from custody. Months later, Sadler filed a petition seeking review of his average weekly wage. PCCC responded with a suspension petition, contending that Sadler was not entitled to retain the benefits he received while incarcerated and asking that his benefits be adjusted to prevent him from being unjustly enriched for the amounts received during that time. The petitions were heard by a workers’ compensation judge, who concluded that PCCC was entitled to reimbursement for benefits paid to Sadler during his pre-conviction incarceration. The judge did not provide for a future credit against benefits to be paid to Sadler, but rather ordered that PCCC should petition the Supersedeas Fund for reimbursement. PCCC appealed to the Workers’ Compensation Appeals Board, and Sadler cross-appealed. The Board modified the workers’ compensation judge’s decision by allowing PCCC to seek a credit against Sadler’s future payments, but affirmed in all other respects. Sadler appealed to the Commonwealth Court. He maintained that his workers’ compensation benefits had been improperly suspended because he spent no time in incarceration after his conviction, as is required pursuant to the clear language of Section 306(a.1). The Commonwealth Court agreed. PCCC appealed, asking the Pennsylvania Supreme Court whether the Commonwealth Court erred in concluding it was not entitled to a reimbursement of the benefits paid to Sadler during his pre-conviction incarceration while awaiting trial. Finding no merit to PCCC's arguments, the Supreme Court affirmed the Commonwealth Court.