An Illinois appellate court recently confirmed that an injured worker can lose temporary total disability (TTD) benefits if they are medically able to return to work within restrictions and refuse a valid light-duty job.
The case involved an insulator who injured his lower back at work and later underwent spinal fusion surgery. After surgery, his doctor cleared him to return to work with limits on lifting and repetitive movements. The employer offered him a light-duty position that fit those limits. The worker did not report to work and later claimed the job was not real and that travel to the job was difficult due to road closures and sitting limits. The employer presented testimony that the light-duty position was legitimate, necessary, and within the medical restrictions.
The worker continued treatment and later reached maximum medical improvement. An independent medical examiner agreed that he could have worked light duty earlier and full duty once treatment ended. The employer later offered full-duty work, which the worker also declined. He instead asked for vocational rehabilitation.
The Workers’ Compensation Commission ruled that the injury was work-related but denied further TTD after the worker refused light-duty work. It also denied vocational rehabilitation and maintenance benefits. The appellate court upheld that decision.
The court explained that TTD benefits are meant to cover periods when an employee cannot work because of the injury. They do not apply when a worker is medically able to perform available work and chooses not to do so. The court also made clear that TTD does not have to continue until maximum medical improvement is reached. Benefits can end earlier if suitable work is offered and refused.
The court rejected the worker’s argument that the light-duty job was a sham. It found the employer’s evidence credible and noted that the worker never meaningfully attempted to return to work, despite multiple offers. The court also upheld the denial of vocational rehabilitation. Those benefits are not automatic and apply only when a worker cannot return to suitable employment and rehabilitation is reasonably likely to improve earning capacity. Here, the evidence showed that suitable work was available and that the worker was capable of performing it.
The decision is a reminder that workers’ compensation benefits depend not only on the existence of an injury, but also on whether the worker remains medically unable to work. When an employer offers legitimate light-duty work within medical restrictions, refusing that work can end wage replacement benefits and limit access to vocational rehabilitation.
