Newton v. Liberty Mutual Insurance

Webb, Judge.

Claimant in this worker’s compensation proceeding asserts error in the change-of-condition rulings below modifying the award from total to partial disability. It is contended that the award was based upon improved economic condition as provided by Code Ann. § 114-709,1 and that in order to meet that section’s criterion of "economic change in condition occasioned by the employee’s return or ability to return to work,” the employer must show the specific dollar amounts of wages that the employee is making or is capable of making after the change in condition.

We disagree, at least…