Cockle v. Dept. of Labor and Industries

Summary

The court held that employer-paid health care coverage is included in the statutory definition of wages used to calculate workers' compensation benefits because it is an in-kind component of lost earning capacity similar to board, housing, and fuel. The court adopted a limiting test requiring that the benefit be readily identifiable, reasonably calculable, and critical to protecting workers' basic health and survival, and required recalculation using the employer's actual premiums. The court affirmed the lower appellate ruling with modified reasoning and remanded to the Department.