Claim of Knouse v. Millshoe
The claimant sustained a work-related back injury in 1987, leading to a permanent partial disability. After returning to light-duty work, he ceased employment in January 1991 following a grand larceny charge to which he later pleaded guilty to petit larceny. He subsequently sought workers' compensation benefits, attributing his inability to work to the 1987 injury. The Workers’ Compensation Board affirmed that the claimant voluntarily withdrew from the labor market, but also apportioned his disability for a specific period as 50% causally related to the 1987 injury. The Appellate Division reversed the Board's determination of voluntary withdrawal, finding it unsupported by substantial evidence given uncontroverted medical opinions of total disability. However, the court affirmed the Board's decision regarding the apportionment of disability and remitted the matter for further proceedings to assess reduced earnings.