Workers' Compensation

IL: AWW Should Not Include Self-Employed Income From Piano Lessons Offered in Claimant’s Home

An Illinois appellate court recently held that the state’s Workers’ Compensation Commission incorrectly calculated the claimant's average weekly wage under 820 ILCS 305/10 by including profits from claimant’s self-employment—providing piano lessons in her home.  The court indicated that those amounts did not represent wages earned while working for an employer, citing Larson’s Workers’ Compensation Law, and Paoletti v. Industrial Comm'n, 279 Ill. App. 3d 988, 996, 665 N.E.2d 507, 512, 216 Ill. Dec. 447 (1996), in which the court excluded income that a claimant earned working as a refuse scavenger. 

Reported by Thomas A. Robinson, J.D.

LexisNexis Online Subscribers: Citations below link to Lexis Advance. Bracketed citations link to

See Mansfield v. Illinois Workers’ Comp. Comm’n, 2013 Ill. App. LEXIS 812 (Nov. 21, 2013) [2013 Ill. App. LEXIS 812 (Nov. 21, 2013)]

See generally Larson’s Workers’ Compensation Law, § 93.01 [93.01]

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law.

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