Aldrich v. City of Lumber City

If the ruling in this case depended solely upon “doing the right thing,” I would have no hesitation in agreeing with the majority that Aldrich ought to, injustice, be required to return every penny that he obtained through his wrongful conduct. But we are bound by the clear mandate of OCGA § 34-9-104 (d) (1), limiting the retroactive application of a modified award:

Subject to the limitation in subsection (a) of this Code section that a change of condition was a change which occurred after the date on which the wage-earning capacity, physical condition, or status of the employee was last…