Kocanowski v. Twp. of Bridgewater

**5Jennifer Kocanowski was a volunteer firefighter for seventeen years and was injured in the course of her duties. Kocanowski applied for and was denied temporary disability benefits because she did not have outside employment. In this appeal, we consider whether volunteer firefighters must be employed to be eligible for temporary disability benefits under the Workers' Compensation Act (Act), N.J.S.A. 34:15-1 to -146.

The Appellate Division affirmed the denial of temporary disability benefits by the Division of Workers' Compensation, finding Kocanowski's unemployment at the time of injury…