Last month, the Pennsylvania Commonwealth Court provided the claimants' bar with a warning regarding the litigation of penalty petitions and the requisite burden of proof when it directed to be reported the matter of Skay v. Borjeson & Maizel v. (Workers' Compensation Appeal Board), No. 999 C.D. 2021 (1/28/22). Skay was originally decided as nonprecedential opinion in May, most likely due to the mundanity of the dispute. It now offers a cautionary tale.