State ex rel. Blabac v. Industrial Commission

Temporary total disability compensation compensates for loss of earnings. State ex rel. Ramirez v. Indus. Comm. (1982), 69 Ohio St.2d 630, 23 O.O.3d 518, 433 N.E.2d 586. Accordingly, TTC is unavailable to one who has returned to work, i.e., is earning wages. Claimant contends that not just any “work” bars TTC but only that which is “substantially gainful employment.” Arguing that his labor was neither “substantial” nor “gainful,” claimant asserts an entitlement to TTC. We find otherwise.

Ramirez, the preeminent TTC case, refers simply to a “return to work,” without any qualification to the…