Articles From James Tyrrell

The Illinois Supreme Court plows through the snowy issue of concurrent employment By James Tyrrell Workers' Compensation Law, June 2005 In a decision noteworthy for both average weekly wage determinations and wage differential awards, the Illinois Supreme Court in Flynn v Industrial Commission, 211 Ill.2d 546, 286 Ill. Dec.62, 813 N.E.2d 119, (June 17, 2004) held that a claimant who sustained serious injury while working a part time job was entitled to a wage differential award based on both the part time job and his regular, though seasonal, work as a truck driver even though he had been temporarily laid off from the driving job at the time of the accident.

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