Claim of King v. Riccelli Enterprises
Claimant Laurence King, a truck driver, sustained neck and back injuries in April 2013 and filed for workers' compensation benefits. Initially, the Workers' Compensation Board ruled he voluntarily withdrew from the labor market after being laid off in November 2013. A WCLJ later found reattachment to the labor market and awarded benefits with an 81% loss of wage-earning capacity. On review, the Board rescinded the reattachment finding and determined a permanent partial disability with a 50% loss of wage-earning capacity. The Appellate Division, Third Department, affirmed the Board's finding of no reattachment to the labor market due to insufficient job search efforts. However, the court reversed the Board's finding of a 50% loss of wage-earning capacity, concluding it was not supported by substantial medical evidence regarding functional ability and loss, and remitted the matter for further proceedings.