In Brown v. Eller Outdoor Advertising Co, 111 Mich. App. 538; 314 N.W.2d 685 (1981), the plaintiff's injury prevented him from moving his body below his neck, except for some "useless" movement in one arm. Id. at 539. He required a great deal of attention and personal care, which his wife provided. Id. at 540. She eventually sought nursing care benefits and the WCAB found that the plaintiff required full-time nursing and custodial care. Brown, 111 Mich. App. at 540-541. The parties disputed whether the plaintiff should receive benefits for full-time care from his wife who, although "on call," performed tasks other than his direct nursing care. The Court reasoned: The fact that a spouse is able to perform household tasks during those times when not actually in attendance with the patient is irrelevant under the circumstances of this case. If the services were provided by someone other than plaintiff's wife, that person would, we assume, pursue his or her own interests within the limits of the job. Such person might read, knit, watch television, or nap during those times in which he or she is simply "on call." The fact that Mrs. Brown might use her "on call" time to perform household tasks does not alter the "nature of the service provided" or the "need" for the service. The Court's reference to household tasks in Kushay was not meant to suggest that under the circumstances of this case the time used in performing each individual service for plaintiff should be added up or that the time used in performing household tasks should be subtracted from the whole. The appeal board found that 24-hour care is needed. Plaintiff's wife provides the service for 17 of those 24 hours and is entitled to payment for the same. Id. at 543.