April 2006 SBH Quarterly Newsletter
PDF FormatWashington Court of Appeals WC Case Law Update
Cockle benefits.
In an unpublished decision, the Court of Appeals found employer paid
non-retirement medical and disability benefits, including social security,
payment for industrial insurance, and medicare were not wages because they
are not consideration the employee receives from his or her employer.
Erakovic v. Dep’t of Labor & Indus., 2006 WL 842405 (Div. I March 13, 2006).
We can expect to see further piecemeal litigation over the type of benefits
that qualify for inclusion in a worker’s wage rate calculation.
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