Board Errs in Applying Single AWW to Worker With Multiple Injuries

A New York appellate court ruled that a worker’s average weekly wage at the time of his injury in 2008 should not be applied to determine his benefits from a 2007 injury, when his earnings were higher. Case: Matter of Grimaldi v. Suffolk County Department of Health, No. 529301, 02/04/2021, published. Facts and procedural history: William Grimaldi worked as a certified nursing aide for the Suffolk County Department of Health. He injured his low back, right hip and right ankle at work in February 2007. In September 2008, Grimaldi injured his right knee while working for a different empl...