Byrd v. State, Department of Administration

The State Department of Administration seeks review of a decision of the Workmen’s Compensation Commission refusing to apportion an award for injuries partially attributable to a work-related injury and partially attributable to a nonworkrelated injury. The commission found no statutory authority permitting such apportionment. We affirm.

Plaintiff, while self-employed as a plumber, sustained back injuries in 1968 which required extensive surgery. Because self-employed persons are not covered by the Workmen’s Compensation Act, no evaluation of this injury was made at the time. Plaintiff was…