In the matter of Kocanowski v. Township of Bridgewater, the NJ Supreme Court in February of 2019 ruled that a volunteer fire fighter who was not otherwise gainfully employed was still entitled to temporary disability benefits after being injured while responding to a fire. 

The Court reasoned that the Workers Compensation Statute created certain protections for volunteer firefighters who were unemployed at the time of their injury.  The statute allows for unemployed volunteer firefighters to recover based on their most recent previous income.

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