Workers' compensation is designed to be a safety net for injured employees, providing financial support during recovery. However, recent legal developments in Ohio have significantly changed how these benefits operate, potentially creating new challenges for injured workers. Let's break it down.
The AutoZone Decision: A Major Shift in Workers' Compensation Law
In November 2024, the Ohio Supreme Court issued a ruling in the AutoZone v. Industrial Commission of Ohio case that dramatically changed how temporary total disability (TTD) compensation works.
First, a little background. In 2020, Ohio enacted R.C. 4123.56(F), which superseded earlier judicial decisions on the voluntary abandonment doctrine. Also known as House Bill 81, the statute reads:
“If an employee is unable to work or suffers a wage loss as the direct result of an impairment arising from an injury or occupational disease, the employee is entitled to receive compensation under this section, provided the employee is otherwise qualified. If an employee is not working or has suffered a wage loss as the direct result of reasons unrelated to the allowed injury or occupational disease, the employee is not eligible to receive compensation under this section. It is the intent of the general assembly to supersede any previous judicial decision that applied the doctrine of voluntary abandonment to a claim brought under this section.”
In the AutoZone case, the claimant injured his right shoulder at work in June 2020, and had a workers’ compensation claim approved for several arm and shoulder conditions. He worked light duty until September 2020, when AutoZone terminated him for violating company policy during a co-worker argument—unrelated to his injury or workers' compensation claim. Though AutoZone approved his November 16, 2020 shoulder surgery under the claim, the claimant also sought TTD compensation for his recovery period following the procedure.
The Ohio Supreme Court took this case on appeal. Now, the AutoZone decision clarifies the application of R.C. 4123.56(F), emphasizing that an employee is ineligible for TTD compensation if they’re not working due to reasons unrelated to the allowed injury.
What Changed?
Before this ruling, employees who were injured and unable to work would receive TTD compensation while recovering. If medical developments revealed a need for more treatment or surgeries after the initial recovery period, they could typically receive renewed TTD benefits during this new treatment phase.
The new AutoZone decision changes this longstanding practice. It indicates that TTD compensation may be denied if an employee isn’t working due to reasons unrelated to the original workplace injury at the time of the new period of disability. This applies even if the new disability is related to the original injury.
Possible Real-World Impact on Injured Workers
Not everyone becomes unemployed because of a workplace argument. However, my legal colleagues and I have serious concerns about employer and Industrial Commission interpretations of the new AutoZone ruling and “voluntary abandonment.”
Consider this scenario: You're an over-the-road truck driver earning $80,000 yearly who suffers a workplace injury. After initial treatment, your benefits are terminated because doctors believe you've reached maximum medical improvement. Later, advanced imaging reveals a tear requiring surgery.
Under the new interpretation, you might be denied renewed TTD benefits for your surgery recovery period because:
- Your benefits were previously terminated.
- The court now expects you to have found alternative employment (such as a minimum-wage greeter position) while awaiting a proper diagnosis for the recently discovered medical issue relating to the original injury.
- The fact you weren't working when asking for renewed benefits—no matter why—can be used to deny your claim.
This creates a harsh situation for specialized workers whose skills don't easily transfer to light-duty positions.
What This Means for You
These changes represent a significant shift in how Ohio workers' compensation has functioned for over a century. The system was designed as a no-fault safety net to provide income support during recovery and prevent injured workers from requiring public assistance.
The practical impact of these rulings includes:
- Potentially large benefit overpayments.
- Difficulty accessing benefits for newly discovered conditions related to original injuries.
- Financial hardship during periods between diagnosis and treatment.
- Challenges finding legal representation, as overpayments reduce the compensation available.
Don't Navigate These Changes Alone
If you've been injured at work, these complex legal changes make professional representation more critical than ever. Our experienced team at Monast Law Office stays current on these developments and can protect your rights and benefits during what’s already a difficult time. Contact us today to schedule a consultation about your workers' compensation claim. We'll explain how these recent decisions might affect your situation and work to ensure you receive the benefits you deserve while dealing with this changing legal landscape.
