New York Sets Boundaries: How to Calculate Schedule Loss of Use of the Shoulder in 2018

The New York Appellate Division has provided direction on what constitutes an improper calculation of the schedule loss of use of a shoulder. In Matter of Maloney v. Wende Correctional Facility, 2018 WL 456207 (January 18, 2013), the claimant injured his right shoulder as a result of a work related accident on July 30, 2013. The claimant’s treating physician rendered a permanency finding of 90 percent schedule loss of use
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