Key Ohio Supreme Court Decision on Workers’ Compensation Benefits
The Ohio Supreme Court recently handed down a decision that may be important to many Ohio workers. In the recent case, the Court held that an injured worker who applied for retirement because of a medical condition unrelated to a workplace injury is no longer able to renew temporary workers’ compensation benefits.
Summary of The Facts
In the facts of the Ohio Supreme Court case, the worker suffered a leg injury on the job in 2004. The worker filed a workers’ compensation claim and was awarded temporary total disability benefits. After several months, the injured employee also applied for disability-retirement from the Ohio Public Employees Retirement System, or OPERS. The OPERS administers pension funds to public employees.
The employee’s application for retirement stated that her inability to work was based solely on a major depressive disorder and did not make mention of the workplace leg injury. Unfortunately, the Industrial Commission of Ohio had disallowed the major depressive disorder from being a part of her workers’ compensation claim.
While the worker’s application for a disability-retirement was under review, the worker continued to receive workers’ compensation benefits for the leg and knee injury, which the Industrial Commission of Ohio allowed. In May 2005, medical doctors indicated that the employee’s leg and knee conditions had improved to the maximum level. Therefore, the worker’s compensation payments to the injured employee stopped abruptly.
Around that time, the employee’s application for disability-retirement was approved with a retirement date that retroactively started on February 1, 2005. The employee at the center of this case has not worked since.
In this complex scenario, the injured employee filed another workers’ compensation application for permanent total disability benefits in 2007 for the knee conditions. The Industrial Commission of Ohio denied the application by concluding that the work-related injury did not preclude the worker from sustaining other employment. According to the decision, the worker had actually left the workforce for a reason other than her work-related injury when she took the disability-retirement benefits.
Ohio Supreme Court Opinion
The Ohio Supreme Court supported the Industrial Commission of Ohio’s decision. The Court found that if an employee leaves the workplace for reasons unrelated to his or her injury, then he or she is no longer entitled to receive worker’s compensation benefits. In this case, the Court believed that the employee’s retirement was not due to the work injury but rather to a major depressive disorder, which the Ohio Industrial Commission specifically excluded from her claim.
The employee contended that the departure from the workforce was involuntary. The court stated that the injured worker’s medical condition involving the knee and leg injury might have precluded the worker from returning to the former position, but it did not medically disqualify her from finding another job. The Court affirmed the judgment of the Court of Appeals by a vote of 7-0.
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