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Workers’ Compensation Supreme Court Opinion

by Oumano, Emily

 

SC20994 - Gardner v. Dept. of Mental Health & Addiction Services (“The sole question in this appeal is whether an administrative law judge with the Workers’ Compensation Commission (commission) has the authority to award ongoing temporary partial incapacity benefits under General Statutes § 31-308 (a) to a claimant who has reached maximum medical improvement and is therefore eligible to receive permanent partial disability benefits under § 31-308 (b). The Appellate Court answered that question in the negative. Gardner v. Dept. of Mental Health & Addiction Services, 223 Conn. App.221, 242–43, 308 A.3d 550 (2024). We disagree with the Appellate Court and conclude that § 31-308 (b) gives an administrative law judge the discretion to award a claimant, after he or she reaches maximum medical improvement, ongoing temporary partial incapacity benefits under § 31-308 (a) in lieu of permanent partial disability benefits under § 31-308 (b), up to the statutory maximum of 520 weeks. Accordingly, we reverse the judgment of the Appellate Court.”)