Lay v. Scott County Sheriff's Department
Jerry Brandon Lay, a deputy sheriff for Scott County Sheriff's Department, was injured in an automobile accident in October 2000, sustaining neck, shoulder, arm, and back injuries. He underwent surgery for a bulging disc and was rated with a 13% whole body disability, reaching maximum medical improvement in January 2002. After initially returning to the Sheriff's Department at the same pay, Lay voluntarily resigned for a higher-paying job, only to be rehired by the Sheriff's Department at a lower wage after his surgery. The trial court awarded Lay 60% permanent partial disability, believing the 2.5 times impairment rating statutory cap did not apply as he was not returned to the same position at the same wage. The Supreme Court reversed this decision, asserting that the 2.5 times cap applies when an employee has a meaningful return to work and resigns for reasons unrelated to the injury, regardless of later returning at a lower wage. Consequently, Lay's award was modified to 32.5% permanent partial disability, which is 2.5 times his 13% impairment rating.