Beecher v. Labor & Industry Review Commission

¶ 1. In this case we revisit the so-called "odd-lot doctrine," an aspect of worker's compensation law dealing with cases of permanent total disability. The issue presented is whether a prima facie case for permanent total disability under the "odd-lot" doctrine must include evidence that the injured employee has made a reasonable effort to find suitable post-injury employment.

*145¶ 2. The odd-lot doctrine is a judge-made adjunct to the law of worker's compensation.1 It represents a modification of the general rule that benefits for permanent total disability compensate an injured worker for loss…