Claim of Leeber v. LILCO
The case involves an appeal from a Workers' Compensation Board decision regarding a claimant exposed to asbestos during employment with LILCO and its successor, resulting in occupational asbestosis and pleural disease. The Workers’ Compensation Law Judge found the claimant permanently partially disabled and that his retirement, though incentivized, was partly due to his disability, thus not a voluntary withdrawal from the labor market. The Board affirmed the disability finding but denied continued compensation after the claimant testified he had not sought post-retirement work. The appellate court reversed, holding that the Board erred by discontinuing awards solely based on the claimant's failure to seek employment post-retirement, as proof that a claimant has not sought work does not, by itself, defeat the inference that reduced earning capacity is due to disability. The matter was remitted for further proceedings consistent with the court's three-step analysis for evaluating voluntary withdrawal from the labor market.