Narrative Opinion Summary
The case involves an appeal by a former corrections officer who sustained an injury during training and sought temporary total disability (TTD) benefits after being terminated for alleged misconduct. The appellant suffered a shoulder injury and underwent multiple surgeries, claiming that he was unable to perform full duties until February 10, 2016. The Labor and Industrial Relations Commission denied his TTD benefits, asserting that his termination was due to misconduct related to improper reporting of absences, not the absences themselves. The court examined the statutory interpretation of 'post-injury misconduct' under Section 287.170.4, which excludes injury-related absences from being considered misconduct unless the employee is certified as capable of working with restrictions. The court found that the Commission misapplied the statute, as the appellant was not able to work with restrictions until the agreed date. Consequently, the court reversed the Commission's decision, reinstating the Administrative Law Judge's award of TTD benefits, as the termination did not preclude his entitlement to benefits. The judgment was remanded with instructions to restore the TTD benefits, emphasizing the statutory protection for injury-related absences. Judges concurred in the decision to reverse and remand the Commission's ruling.
Legal Issues Addressed
Interpretation of 'Post-Injury Misconduct' under Section 287.170.4subscribe to see similar legal issues
Application: The court held that absences due to injury do not constitute misconduct unless the employee is capable of working with restrictions, contrary to the Commission's ruling.
Reasoning: This interpretation misapplies statutory construction principles, as the statute clearly states that absence due to injury is not misconduct unless the employee is capable of working with restrictions.
Standard of Review for Workers' Compensation Casessubscribe to see similar legal issues
Application: The court applied the standard of review under Section 287.495.1, which allows modification or reversal if the Commission acted beyond its powers or if the facts do not support the award.
Reasoning: Section 287.495.1 establishes the standard of review for workers' compensation cases, permitting modification, reversal, remand, or nullification of awards only under specific conditions.
Temporary Total Disability (TTD) Benefitssubscribe to see similar legal issues
Application: The court determined that the Commission erred in denying TTD benefits to the employee, as his absence was due to an injury, and he was not capable of working with restrictions until February 10, 2016.
Reasoning: Hicks filed for compensation for unpaid temporary total disability (TTD) until February 10, 2016. The employer contested this claim, asserting that Hicks was terminated for 'post-injury misconduct' under Section 287.170.4.