Claim of Manning v. Niagara Mohawk Power Corp.
Claimant, rendered quadriplegic and totally disabled, required round-the-clock nursing care. The employer's workers' compensation insurance carrier appealed a Workers' Compensation Board decision, which allowed the claimant to deduct the value of nursing services provided by his spouse from the employer's credit against a third-party settlement, despite no actual payment to the spouse. The carrier argued that expenses must be formally incurred. The court, emphasizing the liberal construction of Workers' Compensation Law, affirmed that such spousal services are creditable. However, the court found the Board erred by not accounting for the spouse's personal time and family duties when valuing her services and by including medical insurance and snow removal costs. Consequently, the Board's amended decision was modified, reversing the direct payment to the spouse and the inclusion of certain expenditures, and the matter was remitted for recalculation of the spouse's services, while affirmed as modified.