Court Rejects Constitutional Challenge to Retroactive Application of Act 111

The Commonwealth Court of Pennsylvania rejected a worker’s constitutional challenge to the retroactive application of Act 111 to his injuries. Case: Barrios v. City of Philadelphia (WCAB), No. 1411 C.D. 2023, 07/11/2025, unpublished. Facts: Joseph Barrios worked for the City of Philadelphia. He injured his back at work in 2016 and began collecting temporary total disability benefits. In March 2022, Barrios underwent an impairment rating evaluation. The evaluator assigned him an impairment rating of 31%, which fell below the threshold allowing the city to modify his status from totally...