In State ex rel. Smith v. Indus. Comm. (1933), 127 Ohio St. 217, 220, 187 N.E. 768, the Supreme Court of Ohio had occasion to interpret and apply the phrase "average weekly wages" as it appeared in Section 1465-79, General Code. According to the Smith court, the statute read: In case of temporary disability, the employee shall receive sixty-six and two-thirds per cent. of his average weekly wages so long as such disability is total. The Smith court also noted that Section 1465-84, General Code, read as follows: The average weekly wage of the injured person at the time of the injury shall be taken as the basis upon which to compute the benefits. Id. In Smith, while employed as volunteer firemen, the relators were seriously injured while en route to a fire. The relators were also concurrently employed as a baker and restaurant worker respectively. The Smith court observed that it cannot seriously be contended that employment as a baker and restaurant worker are in any way related to that of volunteer firemen. As the Smith court put it, does the phrase "average weekly wages" mean the amount received by the relators as firemen, or does it include the amount received as firemen and also the amount accruing from regular occupations? The Smith court recognized that the question to be decided was new in Ohio. It noted that courts of other jurisdictions had held that where an employee engaged in similar work for two or more employers at the time of an injury, his compensation should be based on the amount which he usually earned in the particular kind of employment rather than on the amount he had been receiving from the particular employer in whose service he was engaged at the time of injury. Thus, the Smith court recognized the existence of a so-called similar employment doctrine held by other state jurisdictions in AWW cases. The Smith court explained its interpretation of the phrase "average weekly wages": While it has always been the policy of this court to construe liberally the provisions of the Workmen's Compensation Act in favor of injured employees and their dependents, we should have to resort to a dubious and forced construction of our statutes to hold that the phrase "average weekly wages" as used therein was intended to cover both the earnings of an employee in the particular work he was performing when injured and the remuneration received in a distinct and separate employment, in which he was generally engaged, and which was not connected in any way with the employment in which the injury was suffered. Id. at 221. The Smith court held: We hold, upon the facts in these cases, that the relators are not entitled to awards by the Industrial Commission, as respondent, on a basis including their earnings as a baker and restaurant worker, respectively. Id. The Smith court's syllabus reads: In determining workmen's compensation based upon the average weekly wage under sections 1465-79 and 1465-84, General Code, the Industrial Commission is limited to the average weekly wage received in the employment in which the injury occurred, where claimant was injured while serving as a member of a volunteer fire department, and was also generally engaged in another separate and distinct line of work.