In State ex rel. Wireman v. Indus. Comm. (1990), 49 Ohio St.3d 286, 551 N.E.2d 1265, the claimant had argued that the commission should have applied the special circumstances provision of R.C. 4123.61 because she had not worked 40 hours per week in all of the weeks preceding her injury. The court disagreed with claimant's interpretation because it would define a period of "unemployment," as to all claimants, within the context of a 40-hour week. The court reasoned that, in many cases, a worker defines their own full-time work week at less than 40 hours and that to consider a claimant "unemployed" for the hours that they chose not to work and omit that time from the AWW calculation would provide a windfall to the claimant. As such, the court ultimately indicated that, in some circumstances, part-time employment may constitute a special circumstance. However, the court held that part-time employment is not, per se, a special circumstance.