AFTER REMAND

In the Worker’s Disability Compensation Act,1 the Legislature codifies public policy applicable to, and reflective of, the political give and take of an ongoing economic struggle. Not infrequently, the forum then shifts to the judicial arena. Typically, courts are asked to construe newly enacted legislation and to supply missing pieces of the puzzle that inevitably effect the future direction of the political process. The instant case, however, involves a variation on the usual theme whose seven-year gestation period reflects the significance of the issue to interested parties other than the plaintiff and defendant. In this case we are asked to rediscover in venerable precedent a neglected piece of the puzzle and accordingly limit compensation to partially disabled workers.

In Michigan, disability is wage loss.2 Thus, a worker whose disability is total is one who has lost his wages because of his injury. We acknowledge at the outset, that our approach to the issue presented here is influenced by a strong disinclination to embark on the process of rolling a rock up a hill the Legislature has only recently decided to climb. In this situation the aphorism that what the Legislature has not supplied the Court will not furnish is not only apt but compelling._

*7The issue is what amount of compensation is due an employee whose "incapacity for work resulting from a personal injury is partial,” MCL 418.361(1); MSA 17.237(361X1),3 4where the statute provides that the "weekly loss in wages . . . shall consist of the percentage of the average weekly earnings of the injured employee ... as fairly represents the proportionate extent of the impairment of the employee’s earning capacity in the employment ] ... in which the employee was working at the time of the personal injury.” MCL 418.371(1); MSA 17.237(371)(1).< Specifically, we must determine whether the wcab correctly awarded maximum benefits to the plaintiff, whose disability has been found to be partial, and who has not secured employment since being laid off by defendant several months after injury. We would affirm the award.

Where, on account of an injury, an employee is, in fact, unemployed, the employee is entitled to *8the maximum benefit allowable under § 361(1),5 because the employee is not "able to earn” wages postinjury. The Court of Appeals reduced the maximum benefit amount by estimating the employee’s remaining earning capacity. In directing the agency to apportion benefits, the Court misinterpreted and misapplied the law, and invaded the province of the finder of fact. We would reverse the decision of the Court of Appeals and reinstate the decision of the wcab.

i

Plaintiff, Mark Sobotka, began working for defendant, Chrysler Corporation, in September, 1972, and continued as a Chrysler employee until January, 1979. Defendant employed plaintiff as an inspector in its Hamtramck assembly plant. To perform the inspector’s job, plaintiff was required to bend repeatedly, stand constantly, perform overhead work from a pit underneath a vehicle body, and inspect the underside of vehicle bodies from a kneeling position. In May, 1978, Sobotka was inspecting one vehicle body when another vehicle body moved down the line and pinned him between the two. As a result, he suffered injuries to his back and legs.

Plaintiff’s petition for hearing alleged that he sustained a personal injury to his back and lower extremities that resulted in disability. The petition also alleged a psychiatric occupational disease as a result of the personal injury. The hearing referee found that plaintiff had not sustained his burden of proving either that the work-related injury "continued to disable him beyond the period he *9was paid weekly compensation benefits,” or that any possibly disabling psychiatric condition arose out of or in the course of his employment.

On review, the Worker’s Compensation Appeal Board found that plaintiff’s work-related injury continued to disable him beyond the date that defendant had stopped paying benefits. It ordered defendant to pay benefits for partial disability pursuant to § 361 of the act "not to exceed $153.00 a week until further order of the Bureau.”6

The ensuing history of the case includes three appeals by defendant of orders of the wcab, three orders of remand from the Court of Appeals, one order of remand from this Court, and two opinions of the Court of Appeals before this Court’s order granting leave. Much of that time, as detailed next, was consumed by a protracted disagreement of interpretation between the Court of Appeals and the Bureau of Worker’s Disability Compensation,7 whose provenance is, in all events, unclear. Although reluctant to burden the opinion with *10such detail, the significance of the issue requires inclusion of the tortuous course of this litigation.

A

Defendant’s first appeal challenged, among other things, the clarity of the wcab’s order to pay compensation "not to exceed $153.00.” Plaintiff did not respond. Defendant argued that once the right to compensation had been determined, "the Board’s legal obligation [was] to compute in dollars and cents the amount of partial disability benefits [the employee] is to receive.” Citing Thayer v Britz, 234 Mich 645; 209 NW 50 (1926), and Barrett v Bohn Aluminum & Brass Co, 69 Mich App 636, 641; 245 NW2d 147 (1976), the Court of Appeals agreed and remanded the case to the wcab to "modify its award to specify the extent to which plaintiff’s earning capacity has been impaired, and fix the amount, in dollars and cents, of the weekly benefits due accordingly.” Unpublished order of the Court of Appeals, entered December 23, 1986 (Docket No. 95053). The wcab again awarded the maximum benefit allowable under § 361(1).

Defendant’s second appeal contended that the wcab had equated "able to earn”, under § 361(1) with actual wages earned, and erroneously awarded maximum compensation benefits "pay*11able as if he was totally disabled, . . . despite the fact that the Board finds that the employee is only partially disabled.” Again, the Court of Appeals agreed with defendant, and again the Court of Appeals remanded the ease to the wcab

for the purpose of calculating, in dollars and cents, the proportionate impairment in plaintiff’s earning capacity attributable to his partial disability, in accordance with the guidelines set forth in Trask v Modern Pattern & Machin[e] Co, 222 Mich 692, 697-699 [193 NW 830] (1923). Thayer v Britz, 234 Mich 645, 647 (1926). Plaintiff’s post-injury earnings are merely one factor to be considered; the Appeal Board’s opinion and order of July 31, 1987 treats those post-injury earnings as the sole factor of relevance, contrary to the analysis set forth in Trask, supra. [Unpublished order of the Court of Appeals, entered March 25, 1988 (Docket No. 103031).]

The opinion of the wcab at issue here is the opinion on sécond remand, which reached yet another panel of the wcab. This panel, as had the two before it, also ordered that defendant was to "pay compensation at the rate of $153.00 per week . . . until further order.” Although not a model of clarity, the board’s opinion states:

Based upon the fact that plaintiff has not been able to earn any wages after his January 17, 1979, layoff, the medical testimony of Dr. Larkin, Dr. Goldberg, and Dr. Weisman concerning the nature and extent of plaintiff’s injuries, we find that plaintiff does suffer from a disability which severely limits his ability to engage postemployment.[8] We also find that plaintiff’s proportionate *12impairment in earning capacity attributed to his partial disability is two-thirds of $283.30 or $153.00 per week for two dependents.

Therefore, defendant shall pay plaintiff compensation at the rate of $153.00 per week for two dependents based upon two-thirds of plaintiff’s average weekly wage of $280.30 pursuant to MCL 418.361[(1)]; MSA 17.237(361X1) from February 15, 1979, to March 27, 1981, the date of Closing of Proofs in this matter. Thereafter, defendant shall pay compensation at the rate of $153.00 per week pursuant to MCL 418.361[(1)]; MSA 17.237(361X1) from March 28, 1981, until further order. Interest due and owing on these benefits shall be paid at the rate of 10% per annum. [1989 WCABO 126, 128-129.]

Defendant’s third appeal resulted in another remand to the wcab. This time the Court of Appeals stated it agreed with what it characterized as a "finding” by the wcab that " 'plaintiff’s proportionate impairment in earning capacity attributed to his partial disability is two-thirds of $283.30’ ... as supported by the requisite scintilla of evidence required by Const 1963, art 6, § 28 and § 861 of the Act.” However, the Court of Appeals "corrected” the wcab’s arithmetic. It stated "[t]wo-thirds of $283.30 is not $153, but $188.87. Pursuant to § 361(1), plaintiff’s weekly disability benefit may not exceed two-thirds of his loss in average weekly wage, or $125.91. On remand, the appeal board shall determine plaintiff’s benefit level for two dependents, not to exceed $125.91.” Unpublished order of the Court of Appeals, entered July 26, 1989 (Docket No. 115948). The Court of Appeals denied rehearing.

Plaintiff filed an application for leave to appeal with this Court. In lieu of granting leave to appeal, we vacated the Court of Appeals order of July 26, 1989, and remanded the case to the Court *13of Appeals for plenary consideration. 437 Mich 953 (1991).

B

In its initial decision on remand from this Court, the Court of Appeals affirmed the March 10, 1989, decision of the wcab, which awarded plaintiff $153 per week. It noted that "[t]he record below indicates that plaintiff had a severely limited capacity for employment and has not located employment since his injury.” Unpublished opinion per curiam of the Court of Appeals, issued June 29, 1992 (Docket No. 139553), slip op at 2.9

The defendant moved for rehearing in the Court of Appeals, arguing that the Court had repeated the wcab’s mathematical error. It stated that while the Court’s order of July 26, 1989, had corrected this mathematical error, it had repeated it in its June 29, 1992, decision. The Court granted defendant’s motion for rehearing.

On rehearing, a majority of the Court of Appeals10 characterized the earlier wcab opinions as having awarded the maximum amount allowable on the basis of only plaintiff’s actual postinjury earnings rather than plaintiff’s postinjury earning *14capacity. It interpreted the 1989 wcab opinion as having determined that the proportionate extent of plaintiff’s "impairment in the field of employment in which he was engaged at the time of injury is two-thirds.”11 198 Mich App 455, 463; 499 NW2d 777 (1993). It affirmed the wcab’s factual finding as supported by the requisite evidence, and described that finding as "the proportionate extent of plaintiff’s earning capacity, in light of all relevant factors, is two-thirds of his average weekly wage at the time of the injury.” Id. at 464.12 It then calculated plaintiff’s benefit rate as two-thirds of two-thirds of $283.30, or $126, as rounded off to the nearest dollar. It reasoned that under Trask, Thayer, and Barrett, supra, this was the correct method of calculation, and it ordered that the defendant "pay plaintiff benefits at the rate of $126 a week less any applicable credit for wages actually earned pursuant to § 371(1), until further order of the bureau.” 198 Mich App 465.13

What finally emerges from the multiple appeals and remands is that the plaintiff is partially disabled, that three separate panels of the wcab believe him to be entitled to the maximum allowa*15ble benefit,14 and that a majority of the Court of Appeals judges believe that Trask and Thayer require postinjury calculation of the theoretical extent of the impairment of a partially disabled worker’s earning capacity and compensation on the basis of the application of that figure to average weekly wages.

On plaintiff’s application, we granted leave to appeal. 443 Mich 869 (1993). We would hold that where unemployment of a partially disabled employee is found to be directly attributable to the compensable injury, maximum benefits may be awarded. The agency is not required to estimate the hypothetical extent of impairment. Availability of maximum benefits is a factual issue for factual resolution. We would reverse the decision of the Court of Appeals and remand to the wcab for further proceedings.

ii

Worker’s compensation benefits in Michigan are payable on the basis of wage loss and not on the basis of physical impairment. St. Antoine, Workers’ Compensation in Michigan, Costs, Benefits, and Fairness, A Report to Governor Blanchard, December 12, 1984, p 25. Under a physical impair*16ment system, benefits are based upon a percentage of disability measured in terms of a " 'whole,’ healthy person.” Id. Benefits are paid depending upon the percentage of physical impairment, whether or not there has been, any actual loss in wages. Id.; see also 1C Larson, Workmen’s Compensation, § 57.14(a)-(j), pp 10-69 to 10-104; Gamula v General Motors Corp, 1987 WCABO 2178, 2184, vacated and remanded on other grounds. The physical impairment theory, however, does not "reflect accurately the widely varying economic impact of particular injuries on particular people.” St. Antoine, supra at 25.

Where benefits are awarded on the basis of wage loss, however,

[t]he central idea is that each injured worker will be treated individually, and will receive, in addition to necessary medical expenses, a percentage of his or her actual wage loss (or more precisely, loss of earning capacity), however short or long that loss may continue. The key advantage of this approach, of course, is that it adapts much more readily to the widely varying circumstances of given cases. The lawyer who has lost the little finger on his left hand will receive little or nothing; the concert pianist with the same injury will be entitled to benefits until reasonable alternative employment is made available. . . .

The most important point to be gleaned from all this analysis is that in a wage-loss system, such as Michigan’s, once "disability” is established, the extent of disability makes little or no difference. As long as the disability continues, however slight it may seem in terms of physical impairment, full compensation benefits will at least theoretically be due from the employer. Inability to earn wages in fact will presumptively be the measure of the loss of wage earning capacity. Whether an employee is technically "totally disabled” or "partially disabled” is unimportant as a practical matter. In *17either case he or she will receive full benefits under Michigan law if substitute employment is not proffered. [Id. at 25-26.]

Thus, in a wage-loss system of compensation, there is nothing inherently inconsistent with an award of maximum benefits for partial disability where the board has found that the claimant, because of the injury, is "[un]able to earn” a wage postinjury. Unlike the physical impairment system, the wage-loss system is specifically designed to consider the economic effect of the work-related injury on the individual claimant.

In 1912 the Legislature adopted a wage-loss system of compensating injured workers. 1912 (Ex Sess) PA 10. Indeed, the Legislature specifically provided for an award based upon the injury’s specific economic effect on the worker by basing awards to those partially disabled on the worker’s "average weekly wages which he is able to earn” after the injury. Thus, if an employee is unable to earn wages postinjury because of the work-related injury, the employee is entitled to the maximum benefit.

A

The wcab found that plaintiff is partially disabled. That finding has never been challenged. Therefore it turned to § 361(1) to compute the benefit amount. Under § 361(1) the benefit amount to be awarded is "2/3 of the difference between his average weekly wages before the injury and the average weekly wages which he is able to earn thereafter . . . .”

Defendant contends that under Trask it is error to award a partially disabled worker maximum compensation without consideration of more than *18simply the plaintiff’s postinjury unemployment. The essence of the argument is that a worker who is partially disabled may not suffer a total impairment of wage-earning capacity. Thus, defendant contends that the necessary corollary to a factual finding that any claimant is partially disabled is that the claimant possesses some residual capacity to work and earn wages. Defendant submits that it follows, under §371 and Trask, that residual capacity is translated into a mathematical formulation of a proportionate extent of impairment of earning capacity and that to obtain maximum benefits, the plaintiff must prove an inability to obtain any employment15 because of the work injury.16_

*19Plaintiff responds that § 361(1) should be interpreted to apply to those situations in which an injured employee has been offered and has wrongfully refused postinjury employment or in which an injured employee has voluntarily left postinjury employment. Under this approach, the wages the claimant could have earned in the proffered employment, or in the employment that the claimant voluntarily left, would be determinative of the wage the employee was "able to earn” postinjury. In essence, plaintiff argues that "able to earn” under § 361(1) should be interpreted as actual wages earned, or refused, postinjury.

The Court of Appeals erred in apparently accepting defendant’s contention that as a matter of law a determination of partial disability forecloses a determination of impairment of earning capacity greater than the degree of disability found. The Court of Appeals held that "the average weekly wages [a partially disabled employee] is able to earn thereafter” can never be so low as to allow an award of benefits for partial disability that equals the maximum amount allowable for one totally disabled. The Court of Appeals erroneously presupposes that incapacity for work17 and impairment in earning capacity are synonymous. We *20reject the conclusion because incapacity for work and impairment in earning capacity are not logically synonymous, and because we do not discern a clear legislative direction that they are legally synonymous.

Because the Legislature did not set out a formula through which the wages an employee is "able to earn” postinjury might be calculated, and because the Legislature did not define "able to earn,” we must determine what the Legislature intended by the phrase.18

*21The phrase "able to earn” may be broadly or narrowly interpreted. Regency Inn v Johnson, 422 So 2d 870, 875 (Fla App, 1982) (en banc). "In the broadest sense, 'able to earn’ takes into account many factors, including the availability of jobs . . . .” In its narrowest sense, " 'able to earn’ . . . refer[s] only to the employee’s post-accident physical capabilities.” Id. at 875, n 2. The "broad interpretation is consistent with prior case law, and with the principle that requires a liberal construction in favor of the injured employee.” Id. at 875.

According to Professor Larson, the phrase "able to earn thereafter” is synonymous with the concept of "wage-earning capacity.”19

Even under those statutes which compare, for example, "average monthly wages before the accident” with "the monthly wages he is able to earn thereafter,” the test remains one of capacity. If the legislature had spoken of the wages "he has earned thereafter,” or even the wages "he has been able to earn thereafter,” the comparison of actual wage with actual wage might be indicated. But the concept of wages he "is able” to earn cannot mean definite actual wages alone, especially in the absence of a fixed period of time within which post-injury wages are to be taken as *22controlling. [Larson, supra, § 57.21(a), pp 10-122 to 10-128.][20]

Therefore, an examination of previous decisions discussing "wage-earning capacity” is instructive. At the outset, we again note that, consistent with a wage-loss system of compensation, the concept of "wage-earning capacity ... is a complex of fact issues which are concerned with the nature of the work performed and the continuing availability of work of that kind, and the nature and extent of the disability and the wages earned.” Pulley v Detroit Engineering & Machine Co, 378 Mich 418, 423; 145 NW2d 40 (1966). In short, many factors are considered when attempting to give meaning to the phrase.

What is meant by the term "wage-earning capacity after the injury?” It is not limited to wages actually earned after injury, for such a holding would encourage malingering and compensation is not a pension. On the other hand mere capacity to earn wages, if "nondescript” by reason of injury, affords no measure unless accompanied by opportunity to obtain suitable employment. Opportunity is circumscribed by capacity of the injured and openings to such a wage earner. . . .

An injured person may recover to the point where he can, if favored, perform special service, if such is obtainable, but, if none can be obtained because of his injury, his capacity to work and earn cannot be measured against his incapacity. If his injury isolates him from employment then, of course, he is not to be held to have capacity to work and earn wages. If his injury has reduced his capacity to work and relegated him to the rating of "odd lot” or "nondescript” workers for whom labor openings are extremely limited, then oppor*23tunity, within his capacity, should be made to appear. [Hood v Wyandotte Oil & Fat Co, 272 Mich 190, 192-193; 261 NW 295 (1935). Emphasis added.][21]

Thus, we long ago acknowledged that an employee’s physical "incapacity for work” alone may not accurately reflect the economic effect on a claimant and cannot be mathematically transformed into a benefit amount.22

A broad interpretation of the phrase "able to earn thereafter” is supported by an early opinion of the Industrial Accident Board, precursor of the Worker’s Compensation Appeal Board. The opinion cautioned against reducing compensation on the basis of a partially disabled employee’s physical ability to perform work without more. The Industrial Accident Board recognized:

An employe who is recovering from an injury, and who has recovered so far that the disability is only partial, cannot reasonably be required in his partially disabled condition to go among strangers looking for work. Such requirement would not be reasonable, and the probabilities of his obtaining work if required to so seek it would be very remote. On the other hand if his employer has work suitable for him to perform in his partially disabled condition, and which he can do without *24causing suffering or inconvenience, and offers to give him such work, then it is the duty of such employe to accept the work tendered and thereby reduce the liability for compensation. That if the employer has no such suitable work, or having such work fails to tender it to the injured employe, the compensation cannot be reduced upon the theory that there are classes of work which he is able to do and which he might obtain perhaps if he diligently sought for it, and which on the other hand he might not be able to obtain at all. [Bulletin No 3, Michigan Industrial Accident Board, Partial Disability; Duty to Seek Employment, p 10 (December, 1913). Emphasis added.]

This is not to say that unemployment alone will support an award of maximum benefits for partial disability. Wage loss of a partially disabled worker must be attributable to the claimant’s work-related injury. See Pulley, supra at 428; Kadykowski v Briggs Mfg Co, 304 Mich 503, 506; 8 NW2d 154 (1943); MacDonald v Great Lakes Steel Corp, 274 Mich 701, 703; 265 NW 776 (1936). However, the factfinder may infer " 'that it was [the employee’s] own physical defects which [would have] made the quest a vain one.’ ” Hood, supra at 193, quoting Jordan v Decorative Co, 230 NY 522, 525; 130 NE 634 (1921). It is for this reason that Professor St. Antoine observed that there is little difference between total and partial disability as "a practical matter.”

The phrase "average weekly wages he is able to earn thereafter” does not mean that the unemployed injured worker, whose lack of employment is not due to the work-related injury can only be denied benefits if the employer has offered work to the employee or found work for the employee. "[T]he real inquiry relates to the monetary worth of the injured workman’s services in the open labor market under normal employment condi*25tions.” Jones v Cutler Oil Co, 356 Mich 487, 490; 97 NW2d 74 (1959). However, a disabled worker does not bear the burden of unfavorable economic conditions that further diminish his ability to find suitable work.

B

Given our rejection of the claim that Trask stands for the proposition that the plaintiff must prove the absence of any jobs generally available in the economy, part m, we turn to some observations regarding the burden of proving that post-injury unemployment is due to the work-related injury. Consistent with our prior cases and the provisions of the wdca,23 we would hold, that it is the employee’s burden to show a link between wage loss and the work-related injury. MacDonald, supra at 702-703. "This is merely an application of the rule that the burden of proof of right to compensation and its amount is on the employee.” Id. at 703.

However once the employee shows a work-related injury and subsequent wage loss, the fact-finder may infer that the employee cannot find a job because of the injury. Hood, supra at 193.24 The inference, "in practical effect,” will often carry the day. Where the factfinder is not persuaded, other evidence of the link between unemployment and *26injury may be considered. For example, in the instant case the employee presented evidence that he sought and could not obtain employment and evidence of defendant’s refusal to rehire, which has been described as strong evidence of unemployability. Larson, supra, § 57.61(b), pp 10-398 to 10-405; Leonardo v Uncas Mfg Co, 77 RI 245; 75 A2d 188 (1950).25

Of course, the employer may introduce evidence to refute the inference or to impeach the testimony of the employee. The employer might introduce medical evidence to refute the extent of the employee’s injury. The employer might also introduce evidence of other factors26 that affect the employee’s employability.27 Furthermore, the employer might introduce evidence of jobs offered and rejected, or actually accepted, by the employee.28

*27In a given case the employer might even proffer evidence regarding the availability of specific employment to impeach the plaintiff’s testimony. The factfinder, in its discretion, may accept or reject such testimony on the basis of its bearing on the proposition for which it is offered and the legislative purpose to provide prompt redress for injuries.

We reject the contention, however, that plaintiff bears the burden of producing evidence of jobs he could not perform if theoretically available and that defendant’s offer of evidence of plaintiff’s ability in the abstract to perform some employment rebuts the inference of causation that arises from a showing of unemployment and injury.29 To *28do so would undermine the function of the fact-finder and impermissibly substitute a court-created definition of disability under the rubric of wage-earning capacity. Testimony from vocational experts regarding hypothetical employment is not an element of the claim of impairment of wage-earning capacity.30 We decline to create a presumption in the employer’s favor that if an injured employee is capable of performing some work, appropriate work is regularly available. See Larson, supra, § 57.51(c), pp 10-334 to 10-335. It is not "enough to show that claimant is physically capable of performing light work, and then round out the case for non-compensability by adding a presumption that light work is available.” Id. at § 57.61(c), p 10-437.

m

Because findings of fact are conclusive in the absence of fraud, defendant necessarily contends that the Legislature intended that a finding of partial disability is an inference or conclusion of residual capacity for work, and that § 371(1), Trask, and Thayer require a mathematical caleulation of the proportion of impairment of earning *29capacity that is then transposed onto the benefit calculation. The logic is that if A plus b equals total preinjury capacity for work as measured by average weekly wages, and b is impaired by injury, the benefit amount awarded is the difference.

Trask would allow the board to consider a general decrease or increase31 in wages resulting from changes in the economy as one of the factors to be used to determine the proportionate extent of an impairment of earning capacity. However, that aspect of Trask was mooted by the Legislature,32 as we recognized in Roxbury v Weidman Lumber Co, 268 Mich 596, 599; 256 NW 560 (1934) ("the statute, in designating the wage at the time of injury and constituting such the basic figure, permits no consideration of a general wage decrease”).33

We decline the invitation to breathe new life into Trask by finding in its dormant ashes a requirement of a mathematical calculation of percentage of impairment of earning capacity measured by theoretical ability to exercise residual capacity. Rather, to the extent that Trask has *30contemporary vitality,34 the Court’s directive to the Industrial Accident Board to consider many factors in determining the amount of compensation to be awarded is consistent with the broad interpretation of "able to earn thereafter.” Absence of wages may or may not be attributable to partial disability. All that Trask requires is "a factual link between the partial medical impairment and the reduction of wages.” Leslie, The tortured course of the definition of disability in Michigan workers’ compensation law, past, present and future, 5 Cooley L R 65, 82 (1988).35

IV

Findings of fact made by the wcab are binding on this Court if supported by any evidence in the record. Kostamo v Marquette Iron Mining Co, 405 Mich 105, 135-136; 274 NW2d 411 (1979); MCL 418.861; MSA 17.237(861); Const 1963, art 6, § 28. We may also infer from those findings other findings that were necessary to reach the legal conclu*31sion. Donahoe v Ford Motor Co, 295 Mich 422, 427; 295 NW 211 (1940). In the instant case, the board found as fact from the plaintiff’s testimony regarding his lack of success in finding work36 and from the medical testimony,37 that plaintiff’s ability to earn was severely circumscribed. The wcab could infer38 that his fruitless search for work was *32due to his injury. Hood, supra.

It then became incumbent upon defendant to come forward with evidence to refute plaintiff’s contention. While defendant presented evidence regarding plaintiff’s physical and mental condition, the wcab found that plaintiff had satisfied his burden of proof. The wcab’s finding of fact in this regard is binding on us on review. .

We decline to interpret the wcab opinion in the manner interpreted by the Court of Appeals. The wcab awarded plaintiff the maximum benefit rate allowable under § 361. The wcab considered plaintiff’s testimony and that of the physicians who examined him. It did not, as the Court of Appeals characterized the wcab opinion, "juxtapose” the medical testimony, the lay testimony, and the claimant’s inability to find work. Instead, plaintiff’s proofs established a link between the injury and the unemployment.

We suggest that it lies within the power of the participants in the workers’ compensation system itself to avoid wage loss claims which might be considered unwarranted or excessive by concentrating their efforts on rehabilitation and reemployment of injured workers, rather than by aiming for technical interpretations by which it is hoped to defeat or diminish the recovery of benefits by the injured employee. [Regency Inn, supra, 422 So 2d 880.]

*33V

In sum, a partially disabled employee may be awarded the maximum benefit under §361(1) if the employee shows that wage loss is due to the work-related injury. The determination that an employee is entitled to a benefit award involves the threshold determination of degree of disability and the secondary determination of the amount the employee is able to earn postinjury. Where the employee is unemployed, the determination of what the employee is able to earn after the injury does not require theoretical assessments of jobs the employee could perform if available. Instead, if the unemployment is directly attributable to the injury, the finder of fact should award the maximum benefit available pursuant to §361(1). Thus, we would reverse the decision of the Court of Appeals, reinstate the original decision of the wcab, and remand to the wcac to determine the factual dependency of plaintiff’s wife and to enter an award accordingly. Plaintiff is entitled to ten percent statutory interest.

(separate opinion). I agree with the signers of the lead opinion that the decision of the Court of Appeals should be reversed, that the original decision of the wcab should be reinstated, and that this case should be remanded to the Worker’s Compensation Appellate Commission to determine the factual dependency of Sobotka’s wife and to enter an award with statutory interest.

I write separately because I do not agree with all the analysis and statements in the lead opinion, and because I do not agree with statements in *34the, opinion that concurs in part and dissents in part.

The focus of both the lead and the concurring/ dissenting opinions is on the meaning of the words "able to earn.”1

The lead opinion states: "In essence, plaintiff argues that 'able to earn’ under § 361(1) should be interpreted as actual wages earned, or refused, postinjury.”2 The, lead opinion appears to reject plaintiff’s argument.3

I agree with the plaintiff that "able to earn” means essentially actual wages earned or refused.

*35I

The words "able to earn” appear in 1981 PA 200, amending § 301 of the worker’s compensation act.4 The Legislature there stated that if disability is established, "entitlement” to weekly wage loss benefits "shall be determined” pursuant to the amendatory language. If an injured worker is employed, the wages he actually earns or refuses after the date of the injury is the amount he is "able to earn.”

The Legislature did not intend that the words "able to earn” have one meaning for injured workers who are employed and another meaning for injured workers who do not obtain employment. For both employed and unemployed injured workers, "able to earn” means wages actually earned or refused. The employer is protected from malinger*36ers by the provision5 that denies benefits during the period of a refusal, without good and reasonable cause, by an injured worker of a bona fide offer of reasonable employment from the previous employer, another employer, or through the mesc.

I recognize that Sobotka was injured in 1978, before the enactment of the 1981 amendment. And I also recognize that this meaning was given to the words "able to earn” by an amendment of § 301, and that § 361, where, those words also appear in the context of defining the compensation payable to a partially disabled worker, was not amended. The Legislature did not intend that the words "able to earn” have different meanings under § 361 and § 301.

The Legislature indicated in 1981 what "able to earn” means,6 and, thus, whatever constructions might, but for the 1981 amendment, have been placed upon "able to earn” on the basis of exegeses of earlier case law, those words mean actual wages earned or refused by the injured worker.7

While the lead and the concurring/dissenting opinions modify somewhat the Court of Appeals opinion, they both ignore that the Legislature *37indicated in the 1981 legislation what "able to earn” means.8 The likelihood is that the meaning ascribed to "able to earn” today by the lead and concurring/dissenting opinions will be seen as the last word concerning what those words mean, rather than speaking as of 1978 and as leaving open the question what those words mean beginning March 31, 1982.

That "able to earn” means actual wages earned or refused appears clearly from Dean St. Antoine’s report, written in 1984—three years after the 1981 amendment. Dean St. Antoine stated that the total disability/partial disability distinction is no longer important "as a practical matter.” "In either case,” the injured worker receives full benefits "if substitute employment is not proffered

The most important point to be gleaned from all this analysis is that in a wage-loss system, such as Michigan’s, once "disability” is established, the extent of disability makes little or no difference. As long as the disability continues, however slight it may seem in terms of physical impairment, full compensation benefits will at least theoretically be due from the employer. Inability to earn wages in fact will presumptively be the measure of the loss of wage earning capacity. Whether an employee is technically "totally disabled” or "partially disabled” is unimportant as a practical matter. In either case he or she will receive full beneñts under Michigan law if substitute employment is not proffered.[9] [Emphasis added.]

Dean St. Antoine so reported to the governor in *381984, nine years before the Court of Appeals decided Sobotka v Chrysler Corporation (On Rehearing), 198 Mich App 455; 499 NW2d 777 (1993).

ii

The cases relied on by the Court of Appeals, Trask v Modern Pattern & Machine Co, 222 Mich 692; 193 NW 830 (1923), and Thayer v Britz, 234 Mich 645; 209 NW 50 (1926), decided approximately seventy years ago,10 concerned the computation of benefits in cases where the worker obtained alternative employment. In the instant case, Sobotka has not obtained reemployment. The partially disabled workers in Trask and Thayer were not exposed to the risk of denial of all compensation because of a theoretical opportunity to obtain employment or because of general economic conditions.

The Court of Appeals read Trask and Thayer as requiring that the trier of fact determine a residual wage-earning capacity. The concurring/ dissenting opinion would affirm11 that reading of §§ 361 and 371.12

I agree with the signers of the lead opinion that we should not "breathe new life into Trask by finding in its dormant ashes a requirement of a mathematical calculation of [the] percentage of impairment of earning capacity measured by theoretical ability to exercise residual capacity.”13 I would add that the predicate of Trask and Thayer has been superseded by subsequent amendments of the worker’s compensation act, and that Trask and *39Thayer ceased long ago to have any precedential force.

hi

Dean St. Antoine acknowledged in his report to the Governor the arguments advanced by the employers in this case and by the concurring/ dissenting opinion14 when he reviewed the policy considerations:

The notion that a disability of any degree will create the possibility of life-long benefits will undoubtedly be viewed by the injured worker as no more than his fair entitlement. In his continuing incapacity, or even recurrence of incapacity, to match his wage level at the time of injury can be traced back to that initial injury, why should not his entitlement to compensation parallel that loss of earnings or of earning capacity? On the other hand, what the employer sees is an employee with only a moderate physical impairment who is hardly worse off, in the sense of employability, than many other fellow unemployed workers in a recessionary or underemploying economy. In essence, the employer sees the workers’ compensation system being transformed into a specialized high-beneñt unemployment compensation program.

The sad fact, as I see it, is that both the employee and the employer are right, from their particular perspectives. The Michigan system should seem entirely fair to all parties in periods of relatively full employment. Either the case law or the new statutory definition of "disability” may or may not be rather generous in sweeping injured workers within the coverage of the system. But such workers lose their entitlement to beneñts if they unreasonably refuse bona ñde offers of alternative employment, and the compensátion due *40them is reduced proportionately by their earnings in any employment. The rub comes when that other employment is not available, or is available only intermittently.[15] [Emphasis added.]

Dean St. Antoine clearly saw that under the statute as amended in 1981, the employer would be required to pay benefits although no employment was available because of economic conditions.

I read Dean St. Antoine’s review of Michigan law as an attempt to accurately state Michigan’s worker’s compensation law as it was when he reported to Governor Blanchard. In so reporting, he was, of course, not speaking for this Court, but he was reporting on the basis of the commonly held view of what the law was. Justice Oliver Wendell Holmes, Jr., in his oft-quoted dictum, observed: "The prophecies of what the courts will do in fact, and nothing more pretentious, are what I mean by the law.”16

Dean St. Antoine made his prophecy on the basis of the statute, the history of its amendment, case law, and the practice as understood by practitioners representing employers as well as workers. Dean St. Antoine could not have anticipated or prophesied the revisionist approach reflected in the Court of Appeals opinion, as modified by the lead and concurring/dissenting opinions.

Absent actual employment or refusal of an offer of reasonable employment, a disabled worker should be paid the statutorily prescribed benefits without regard to factors made relevant by the lead and concurring/dissenting opinions.

*41IV

Dean St. Antoine’s report recommended fundamental procedural changes to cope with the backlog of the Worker’s Compensation Appeal Board that had reached almost 7,000 by 1984, roughly a five-year caseload. The sea change in the determination of eligibility for worker’s compensation benefits that would be brought about by the Court of Appeals opinion in Sobotka, as modified by the analysis in the concurring/dissenting opinion, would assuredly result in undermining that legislative effort to reduce the backlog.17

Under the concurring/dissenting opinion, employers, motivated by a desire to limit their worker’s compensation liability, would be permitted and even encouraged to hire vocational and other expert witnesses to testify in cases with significant liability that postinjury unemployment is not presumptively due to the injury, but to "the economy.”18

The analysis adopted in the concurring/dissenting opinion would greatly reduce the force of the remedial nature of the statute. The push is on to move disabled workers from totally disabled to partially disabled, and then to deny benefits because, as a result of economic conditions, no jobs are available. Injured workers would be required, in practice, to disprove that economic factors are related to continued unemployment, placing on *42them an enormous factual and legal burden.19 The resultant change in practice was not contemplated by the Legislature. Nor is it necessary to resolution of the instant case, now pending for a substantial part of the sixteen years since injury.

(concurring in part and dissenting in part). While I concur in some of the reasoning of the lead opinion, namely, that an inference of total impairment of earning capacity is permitted where a partially disabled employee has not performed any work, I write separately to express my understanding that the Worker’s Disability Compensation Act 1 requires the finder of fact to determine the extent the partial injury has impaired wage-earning capacity. Although I concur with the lead opinion for reversal of the rationale employed by the Court of Appeals, I dissent from affirmance of the wcab. Because the board has never stated that it found total impairment of earning capacity, I would remand for a statement of the extent earning capacity has been impaired.

Although the wcab found the wage loss to be linked to the partial disability, the record does not establish that it found the partial disability to have entirely caused total impairment of earning capacity. It is not sufficient to find some connection between wage loss and partial disability. For a claimant to obtain maximum benefits, it must be found that the actual wage loss is entirely caused by the work-related injury. If wage loss is only *43partially due to the work-related injury, then partial benefits are in order.

Unlike the lead opinion, I would not find any link between partial disability and total unemployment to be sufficient to establish the maximum award under MCL 418.361(1); MSA 17.237(361)(1).2 Only where the finder of fact determines the partial disability to be the sole reason for total unemployment should full benefits be awarded.

i

In the present case, the claimant, an unskilled laborer, has established a partial disability caused, by a work-related incident. The claimant has had no actual earnings. The defendant employer presented evidence of reasons other than the injury to account for the plaintiff’s unemployment. The plaintiff suffered from a nonwork-related, serious psychological condition (manic depression or schizophrenia) before and following the work-related back injury. After his initial recovery from the workplace accident, the plaintiff tried to return to his former employment, but complained of pain and was discharged. The plaintiff contested the discharge and was eventually reinstated. However, by the time the plaintiff was reinstated, his position had been eliminated because of plant-wide layoffs. When questioned by defendant about efforts to find other employment after he was unable to be reinstated, the plaintiff could only specify one unsuccessful application to Burger King.3

*44The defendant employer’s position is that it is error to award full benefits on a finding of partial disability unless the plaintiff proves he has no residual earning capacity. Plaintiff contends that where there is any partial disability, maximum benefits should be automatically awarded unless the claimant has been offered and has wrongfully refused postinjury employment. It is my conclusion that both positions are inaccurate. The proper interpretation of § 361(1) lies somewhere in the middle of the two arguments.

I agree with the lead opinion that the Court of Appeals erred in presupposing the partial disability determination to be synonymous with the extent earning capacity has been impaired. While I agree that the determination of partial disability does not foreclose a determination of total impairment of earning capacity as a matter of law, neither does the determination of partial disability establish total impairment as a matter of law. I disagree with the lead opinion to the extent it is suggesting that partial disability is to be considered the equivalent of total impairment. Neither interpretation is true to the statute as it read when Sobotka was injured.4

Even the most casual reading of the statute compels the conclusion that the factfinder in a worker’s compensation case at the time this case was tried was instructed to assess the residual earning capacity at the first hearing. Should a finder of fact determine that a partial disability has only partially impaired earning capacity, in that there are other reasons for total postinjury *45unemployment, compensation should be limited to the extent the injury has caused unemployment.5

I would agree that under a wage-loss system such as ours, the proper measure of compensation depends on the economic effect of the work-related injury on the individual claimant. The lead opinion states "[w]here, on account of an injury, an employee is, in fact, unemployed, the employee is entitled to the maximum benefit allowable under §361(1) . . . .” Ante, pp 7-8. The lead opinion further states "we long ago acknowledged that an employee’s physical 'incapacity for work’ alone may not accurately reflect the economic effect on a claimant and cannot be mathematically transformed into a benefit amount.” Ante, p 23.1 do not dispute that we recognized early in worker’s compensation law that a partially disabled person faces hurdles to future employment that extend beyond the physical limitations experienced by the worker. Hood v Wyandotte Oil & Fat Co, 272 Mich 190, 193; 261 NW 295 (1935) (quoting Jordan v Decorative Co, 230 NY 522, 525; 130 NE 634 *46[1921]) (" 'Failure to find work stands upon a different basis when the labor is unmarketable because of the condition of the laborer’ ”).

It does not follow, however, that because we acknowledge disabled persons face additional hurdles, we acquiesce in the abandonment of any attempt to determine residual earning capacity. "[Compensation law is to be construed liberally to provide indemnity for accidents peculiarly incidental to employment, but it was not intended to be health, accident and old age insurance and spread general protection over risks common to all and not arising out of and in the course of employment.” Simpson v Lee & Cady, 294 Mich 460, 463; 293 NW 718 (1940). The purpose of worker’s compensation is to approximate the amount of wage loss attributable to the work injury. Foley v Detroit United Railway, 190 Mich 507, 515; 157 NW 45 (1916).

This is not the first time this Court has been asked to interpret what factors are appropriate to consider when determining impairment of earning capacity6 or whether the "able to earn thereafter” language of § 361(1) refers to actual wages alone.7 Trask v Modern Pattern & Machine Co, 222 Mich *47692, 696; 193 NW 830 (1923), established that an employer is not liable for lost wages that were caused by a downturn in the economy rather than the partial disability.8 In Thayer v Britz, 234 Mich 645; 209 NW 50 (1926), we remanded to the precursor of the board for a determination of impairment of earning capacity. "Having found partial disability it was the duty of the board to compute in dollars and cents the proportionate extent of the impairment of his earning capacity in accordance with [what is presently §§ 361 and 371].” Id., p 647. While this principle may have been long neglected by the wcab,9 it has been applied by the Court of Appeals10 and has not been explicitly *48overruled by this Court. 11

The first opportunity for this Court to interpret the 1927 amendment of the statute was in Roxbury v Weidman Lumber Co, 268 Mich 596; 256 NW 560 (1934). We ordered an award of less than the maximum benefit to an employee who was receiving a lower wage when she returned to the same position she had held at the time of injury. We again addressed wage-earning capacity after the 1927 amendment. Hood v Wyandotte Oil & Fat Co, supra.12 In Hood, the employer asserted that the employee whose physical disability precluded a return to preinjury employment and who had no actual postinjury earnings had the training and residual capacity to resume work as a barber. We stated that wage-earning capacity is not limited to wages actually earned because such a holding would encourage malingering and transform com*49pensation into a pension. Id., p. 192. There is " 'no ground for compensation if the failure [to find work] has its origin in general business conditions ....’” Id., p 193 (quoting Jordan v Decorative Co, supra, p 525). To award maximum benefits, it must be determined that the employee’s earning capacity in other fields is circumscribed by the disability. Id., p 194.

We ordered an award of less than the maximum benefit where an employee received no actual postinjury earnings. Coleman v Whitehead & Kales Co, 268 Mich 412; 256 NW 467 (1934). The award represented the diminution of an employee’s earning power when his earning capacity at the time of the injury was compared to his earning capacity when seeking compensation. Id., p 414. Reversing an award based solely on the difference between preinjury and postinjury earnings without ascertaining earning capacity, we repeated the requirement in Barnot v Ford Motor Co, 282 Mich 37, 39; 275 NW 758 (1937), that in order to hold the employer liable for the loss, the difference between preinjury and postinjury wage must be attributable to the injury:

This found and measured his partial disability by decreased earnings rather than by capacity to work and made defendant an insurer required to make up the difference between what plaintiff earned before and after the accident. Such is not the test any more than mere inability to get work. The test to be applied is whether his injury has decreased his capacity to work as before and, therefore, he has earned less by reason of his physical disability and defendant should be made to respond for the loss occasioned by the injury. [Emphasis added.]

While we excused the board’s failure to make a *50specific finding regarding impairment of earning capacity in Donahoe v Ford Motor Co, 295 Mich 422; 295 NW 211 (1940), we did so because the award of the maximum amount could not have exceeded the former wage when added to residual earning capacity.13

We repeated in Pigue v General Motors Corp, 317 Mich 311, 316-317; 26 NW2d 900 (1947), that to limit earning capacity to wages actually earned would encourage malingering, and we stated again that the determination of earning capacity must include an examination of the employee’s opportunity to obtain suitable employment. In Pulley v Detroit Engineering & Machine Co, 378 Mich 418; 145 NW2d 40 (1966), we stated that what the partially disabled employee is able to earn thereafter is a matter of proof and a question of fact. "[I]f the bare elements of proof of what the employee was paid were construed as establishing his 'earning capacity’ the whole purpose of the act would be vitiated.” Id., p 423.

If, as this Court held in Jones v Cutler Oil Co, 356 Mich 487, 490; 97 NW2d 74 (1959), "the real inquiry relates to the monetary worth of the injured workman’s services in the open labor market under normal employment conditions,” then an employer certainly should be able to refute the inference that the partial disability solely caused the employee’s total lack of earnings. Where an employer suggests that other factors, including general economic conditions, have caused or contributed to the loss of wages, the magistrate or the board must go further than finding partial disability and some link to the unemployment—the board must compute impairment of earning capacity^_

*51Judicial interpretation is not warranted whenever the language of a statute is clear and unambiguous. Livonia v Dep’t of Social Services, 423 Mich 466, 487; 378 NW2d 402 (1985); Achtenberg v East Lansing, 421 Mich 765, 770; 364 NW2d 277 (1985). Only if the meaning of a statute is unclear, should a court undertake an analysis of the reasonableness of any given construction. State Treasurer v Wilson, 423 Mich 138, 144; 377 NW2d 703 (1985). It is apparent from the ordinary meaning of the words chosen by the Legislature that the central focus of § 361(1) is on ability or potential for employment and not actual postinjury earnings. Had the Legislature intended to limit earning capacity to actual wages earned or an offer of employment by the employer, the Legislature surely would have used words to that effect.

Properly interpreted, "able to earn thereafter” provides for consideration of economic conditions and other factors insofar as they reflect the availability or unavailability of work for partially disabled employees. Any interpretation that holds that the extent of disability is irrelevant as long as there is some disability and actual wage loss would be contrary to the plain meaning of the statute and would undermine the purpose of worker’s compensation.14

In further support of my belief that the fact-finder is instructed by statute to determine residual earning capacity at the first hearing, I point to the inherent difference between partial and total disability. Section 351 separately and dis*52tinctly provides for the treatment of totally disabled workers. The lead opinion treats whether an employee is totally or partially disabled as irrelevant as a practical matter. If the lead opinion is correct in its dismissal of the possibility of partial benefits in this case, it is hard to fathom why the Legislature would have made the distinction when it enacted § 361(1).15 Where an employee proves an inability to obtain any work because of a partial disability, the maximum rate of compensation should be awarded. Where the lack of opportunity to earn is unrelated to the partial disability, then the lack of earnings should not be compensable under the Worker’s Disability Compensation Act.16

I agree with the conclusion of the lead opinion that the employee should not bear the burden of unfavorable economic conditions only to the extent *53that it is addressing the effect of unfavorable economic conditions in combination with the partial disability that further diminishes the claimant’s ability to find suitable work. Powell v Casco Nelmor Corp, 406 Mich 332, 351; 279 NW2d 769 (1979). The employer should not bear the burden of unfavorable economic conditions that function independently to preclude the claimant from finding employment where the Legislature provided for an assessment of the effect of partial disability on earning capacity. In the appropriate case, the defendant should be able to introduce evidence to support an inference that economic conditions, or other factors independent of the partial disability, are actually responsible for total unemployment. To hold otherwise transforms worker’s compensation insurance into unemployment insurance.

The lead opinion states that the employer may refute the causal connection between partial disability and unemployment with evidence that other factors are the cause of the unemployment.17 I would agree. The result the lead opinion would reach in affirming the board’s lack of any specific determination of earning impairment beyond finding partial disability suggests that measuring the link between the absence of wages and the partial disability is an all-or-nothing proposition on the issue of causation.18 I would reject any all-or-nothing interpretation of the relevancy of the effect of other factors on earning capacity that is suggested *54in the lead opinion. Such an approach ignores that the absence of wages may be only partially attributable to disability. Trask and its progeny require that the extent of the factual link be measured, and only that percentage of actual wage loss be assessed against the employer and ultimately the consumer.

Under the statute, a magistrate could properly find that the partial injury precludes employment to a certain degree, but that other factors, including economic conditions, contribute to the unemployment, and order compensation only to the extent that the work-related injury has precluded employment.

After the second remand from the Court of Appeals in which the board was once again directed to state the residual earning capacity, the board wrote that the partial injury "severely limits [the employee’s] ability to engage post-employment.” 1989 WCABO 126, 128. Although the Court of Appeals has asked the board three times to determine the precise effect the injury has had on earning capacity in accordance with Trask and Thayer, the board insists on administering the statute under an interpretation that provides full benefits for any impairment, no matter how minimal. A precise determination of the extent of impairment is therefore irrelevant in its view. While a certain amount of deference is generally due an administrative interpretation of the application of the administrative code governing its own action, that deference does not extend to administrators ignoring the statute’s plain language and this Court’s precedence and directives.19

*55The required determination of earning capacity is no doubt a difficult task, but it is no more difficult or speculative than determining whether any given disability is the result of a workplace incident. Further, the Legislature has stated in clear language that such a determination is to be made. It is no excuse to tell employers they are to be liable for total wage loss regardless of what the Legislature said in § 361(1) because it is not easy to figure out what the employer should be responsible for.

Accordingly, I would reverse the decision of the Court of Appeals and remand the case to the wcac for a determination of the extent that the partial disability has caused the unemployment. While an inference of one hundred percent would be supported where an employee demonstrates partial wage loss and total unemployment, the record does not show that the finder of fact made any determination of the extent the partial injury contributed to total unemployability.20_

*56Only if the board finds that the partial disability caused total impairment should the maximum award be ordered. If the board determines the work-related injury caused part of the unemployment, the statute requires compensation to be made for that part only.