As noted in an earlier article, one issue which has received considerable attention in terms of equal protection challenges in US courts is that concerning the offset of one type of social security benefits with worker’s compensation payments. The Supreme Court in Richardson v Belcher upheld the reduction in social security disability insurance because of receipt of a state worker’s compensation payment as rationally based and free from invidious discrimination. The Court and various federal courts of appeals have subsequently shown little interest in subjecting such offset provisions to more than a minimal level of scrutiny. State courts have also generally upheld provisions offsetting workers compensation and different forms of disability benefits. However, some State courts have continued to show considerable concern about attempts to offset old age and retirement benefits with worker’s compensation schemes and have, in a number of cases, struck down such provisions as unconstitutional under either the Federal or State constitutions (although a majority of courts in cases raising the issue have upheld such provisions). In 2009, this trend continued with the Utah Supreme Court in Merrill striking down such an offsetting provision while, in contrast, the Montana Supreme Court upheld such an offset in Satterlee. More recently, the Montana court has come to a different conclusion as regards rehabilitation benefits in Caldwell while the en banc Commonwealth Court of Pennsylvania has rejected the Merrill approach and upheld an offset in Caputo. This note outlines the two most recent cases and then analyses their decisions in the light of the broader jurisprudence.