Matter of Canela (Sky Chefs, Inc.)
Rolando Canela, a caterer, sustained a work-related back injury in May 2018. He was awarded temporary partial disability benefits, but the employer and its carrier (appellants) challenged the Workers' Compensation Board's finding that he maintained attachment to the labor market. Appellants argued Canela refused a light-duty offer and had an inadequate independent job search. The Board, however, found no specific light-duty offer and deemed his job search, involving about two dozen online applications, sufficiently diligent. The Appellate Division, Third Department, affirmed the Board's decision, concluding that substantial evidence supported its determination that Canela did not reject a suitable work offer and demonstrated an attachment to the labor market.