The fighting issue was whether he was also entitled to recover for wage loss. [ Id. at 60.] In Drouillard v Stroh Brewery Co, 449 Mich. 293, 299-301; 536 N.W.2d 530 (1995), this Court observed: Because most social legislation in Michigan was implemented in unrelated fragments, failure to coordinate resulted in an accumulation of benefits.

American Civil Liberties Union of Mich. v Calhoun Co Sheriff's Office, ___Mich ___, ___; ___ N.W.2d ___ (2022) (Docket No. 163235) (ACLU of Mich); slip op at 5; Dep't of Talent & Economic Dev/Unemployment Ins Agency v Great Oaks Country Club, Inc, 507 Mich. 212, 226; 968 N.W.2d 336 (2021). People v Dowdy, 489 Mich. 373, 379; 802 N.W.2d 239 (2011), quoting Drouillard v Stroh Brewery Co, 449 Mich. 293, 302; 536 N.W.2d 530 (1995). See also City of Lansing v Lansing Twp, 356 Mich. 641, 648; 97 N.W.2d 804 (1959).

When a statute's language is clear and unambiguous, this Court will enforce that statute as written. People v Dowdy, 489 Mich 373, 379; 802 NW2d 239 (2011), quoting Drouillard v Stroh Brewery Co, 449 Mich 293, 302; 536 NW2d 530 (1995). People v Kowalski, 489 Mich 488, 498; 803 NW2d 200 (2011).

City of Taylor v Detroit Edison Co, 475 Mich 109, 115; 715 NW2d 28 (2006).Drouillard v Stroh Brewery Co, 449 Mich 293, 302; 536 NW2d 530 (1995).People v Francisco, 474 Mich 82, 87; 711 NW2d 44 (2006).

It is a long-accepted principle of statutory construction that the court must construe a statute so as to give full effect to all its provisions. Drouillard v. Stroh Brewery Co, 449 Mich 293, 302; 536 NW2d 530 (1995). The Court of Appeals erred in not considering the language of MCL 777.43(2)(a), above, which specifies that the five-year period must include the sentencing offense.

This Court also stated that its interpretation was consistent with the language of MCL 418.354(1)(d), limiting coordination to the after-tax amount of the pension: See, generally, Drouillard v. Stroh Brewery Co, 449 Mich. 293, 304-305; 536 N.W.2d 530 (1995) (holding that the employer could coordinate a lump-sum pension distribution with worker's compensation benefits where the employee had been "forced" to accept the pension distribution). By reason of the tax-free aspect of a rollover into an ira, there is no taxable event and, hence, no tax or "after-tax amount" that is "received or being received."

As we noted in People v. Aaron,Drouillard v. Stroh Brewery Co, 449 Mich. 293, 302; 536 N.W.2d 530 (1995). Const 1963, art 3, § 7; People v. Stevenson, 416 Mich. 383; 331 N.W.2d 143 (1982).

Further, a statute must be construed so as to give every word meaning. "[I]n the interpretation of statutes, effect must be given, if possible, to every word, sentence and section . . .. " Drouillard v Stroh Brewery Co, 449 Mich. 293, 303; 536 N.W.2d 530 (1995). The result reached by the majority renders the word "past" in the exception nugatory, thereby violating this rule of statutory construction.

On this basis, it appears that the Legislature's enactment of MCL 418.358; MSA 17.237(358) alone undermines Pennington. We, therefore, find the present case to be squarely within the Parker decision justifying deviation from stare decisis. Our conclusion is supported by our most recent pronouncement on this issue in Drouillard v Stroh Brewery Co, 449 Mich. 293, 299; 536 N.W.2d 530 (1995): "Worker's compensation is one unit in a loosely connected system of wage-loss protection that also includes unemployment compensation. . . ." In Leizerman v First Flight Freight Service, 424 Mich. 463, 473-474; 381 N.W.2d 386 (1985), this Court held that Michigan law "only compensates for lost wages.

An employee can experience only one wage loss and, in any logical or coherent system, should receive only one wage-loss benefit at any one time. [ Drouillard v. Stroh Brewery Co. , 449 Mich. 293, 299, 536 N.W.2d 530 (1995) (citation omitted).] Thus, "[a]fter discovering that many employers were paying more than once to compensate a disabled employee's lost earning potential when that employee was also receiving disability pension benefits, the Legislature, in 1981, enacted MCL 418.354."