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Workmen's Compensation - Benefits - Exclusiveness Of Schedule Provision, Mark Shaevsky

Michigan Law Review

Plaintiff received benefits under the schedule provisions of the Michigan workmen's compensation statute for amputation of four fingers and one leg. Upon the expiration of payments the hearing officer awarded additional recovery for plaintiff's total disability resulting from the amputation. After subtracting compensation received for the specified losses, the appeal board affirmed. On appeal to the supreme court, held, affirmed by an equally divided court. The legislature intended the schedule provisions to be irreducible minimum awards, not exclusive compensation. Curtis v. Hayes Wheel Co., which construed schedule allowances as barring further recovery for total and permanent disability, is …