State ex rel. Ford Motor Co. v. Indus. Comm

In State ex rel. Ford Motor Co. v. Indus. Comm., 98 Ohio St.3d 20, 2002 Ohio 7038, 780 N.E.2d 1016, the court determined that the claimant's activities did not, in and of themselves, generate any income; instead, the claimant's activities produced money only secondarily. In that case, the claimant owned a lawn care business. As a result of his work-injury with his employer, claimant was not able to continue physically handling his lawn care business and hired three additional employees. The court focused on the following relevant factors: the claimant had removed himself from the physical labor of his business and hired other people to perform that labor; the claimant was not actively engaged in the business; and the claimant's activities, in and of themselves, did not generate income.