In Gordon v Henry Ford Health System, an unpublished decision of the Michigan Court of Appeals (COA case #244596, 11/18/03), the Court held that the employer was entitled to credit against wage loss benefits it was paying for a work-related disability for the employee’s subsequent self-employment earnings where she actively participated in the operation of her business. The employee was receiving wage loss benefits from the employer for a work-related injury. Subsequently, she became the owner/operator of two group homes. The Court found that the homes were not merely an investment from which plaintiff derived passive income. Rather, the employee actively participated in the operation of the business. Therefore, the Court held that the employer was entitled to reduce the employee’s wage loss benefits for the employee’s self-employment earnings.