Special Consideration Doesn't Preclude SLU Value for Different Diagnosis

A New York appellate court ruled that the application of a special consideration did not preclude a schedule loss of use value for a worker’s shoulder impairment resulting from a diagnosis not governed by the special consideration at issue. Case: Matter of Garrow v. Lowe’s Home Centers Inc., No. CV-23-0067, 05/16/2024, published. Facts: Raymond Garrow worked for Lowe's Home Centers Inc. as a delivery driver. He injured his left arm in June 2004 while moving a refrigerator. Lowe’s accepted liability for a shoulder strain and a partially ruptured bicep tendon. In 2014, ...