Denny Lee Rhodes v. Capital City Insurance Company and James Farmer, Director, Department of Labor, Second Injury Fund
The central issue in this case was whether permanent total disability benefits should begin from the date of maximum medical improvement (MMI) or the last day the employee was able to work due to the injury. The trial court determined that benefits should be paid from the last day of work, prompting the employee to appeal, contending he was totally disabled from his MMI date. He argued that he should collect benefits for the period between MMI and when he ultimately stopped working, as he only worked in a limited capacity. The Supreme Court affirmed the trial court's decision, noting that the employee continued to earn income during the disputed period. The court found no evidence presented that he was unemployable in the general workforce, thus concluding he did not meet the statutory definition of permanent total disability until he ceased working entirely.