Metallus must keep paying disability benefits to retired injured worker

Weeks later, while collecting those benefits, she finalized an early full-pension retirement, effective November 28, 2022. She had told the employer’s third-party administrator months earlier that she planned to retire before December to maximize her pension, and testified the lump sum came to more than $100,000. The employer then moved to end her TTD, arguing she had voluntarily abandoned her job. 

The commission agreed and terminated the payments. Its order leaned on R.C. 4123.56(F), a provision Ohio lawmakers added to scrap the old “voluntary abandonment” rule – the idea that quitting or retiring could forfeit benefits – and replace it with a “direct result” test. A worker stays eligible only when the injury, not something unrelated, directly causes the lost wages. 

A magistrate had recommended denying the worker’s challenge. He leaned on the Ohio Supreme Court’s 2024 AutoZone ruling, where an employee was fired for policy violations before his surgery. Because that worker had already lost his job, the court found his lost wages flowed from the firing, not the injury. 

The appeals court saw the opposite pattern here. This worker had surgery first and was already receiving TTD when she retired. Her retirement, the court said, “did not become the direct cause of her wage loss” because she “was already unable to work.” The court called it “the chronological reverse” of AutoZone. 

For HR and benefits teams, the decision draws a sharp line. A retirement or job exit that follows a disabling, injury-related surgery may not break the causal chain – and may not justify stopping TTD. Order matters, as does documenting when a worker became unable to work and why.