Claim of Barnard v. John Mezzalingua Associates, Inc.
The claimant sustained work-related injuries to both hands in 2004 and applied for workers’ compensation benefits. Initially, a Workers’ Compensation Law Judge set the average weekly wage at $447.10 using a 260-multiple. The employer appealed, arguing for a lower wage based on actual earnings. The Workers’ Compensation Board subsequently determined a miscalculation occurred and established the average weekly wage at $343.92, applying a 200-multiple under Workers’ Compensation Law § 14 (3) because the claimant did not work substantially the whole year. The Appellate Division affirmed the Board's decision, finding the 200-multiple accurately reflected the claimant's earning capacity, as she was a full-time employee who did not voluntarily limit her availability.