Stozicki v. Allied Paper Co., Inc.

The issue in this case concerns the relationship between two provisions of the Worker’s Compensation Disability Act, § 354,1 which permits coordination of benefits with certain other payments, and the “age 65 reduction” provision of § 357.2 Relying on the Court of Appeals decision in Saraski v Dexter Davison Kosher Meat & Poultry, 206 Mich App 347; 520 NW2d 383 (1994), the Worker’s Compensation Appellate Commission decided that once having reduced benefits under § 357, an employer cannot then switch to coordination of benefits under § 354. We conclude that Saraski misinterpreted the…