Petrillo v. Cooke
Claimant, a funeral director, sustained a work-related back and knee injury in 1994, leading to workers' compensation benefits. After being laid off due to downsizing and deemed permanently partially disabled, she retrained as a paralegal. In 2005, the employer and carrier sought to suspend benefits, alleging she voluntarily withdrew from the labor market. A Workers' Compensation Law Judge and the Board affirmed this, suspending payments. The Appellate Division affirmed the Board's decision, finding substantial evidence for voluntary withdrawal based on claimant's limited job search, her statement to a physician that she "elected to not work in the paralegal field," and her failure to prove a link between her disability and her inability to find paralegal employment.