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Feb 19, 2025

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence

In a decision that reinforces the potential consequences of misrepresenting one’s physical condition, a New York appellate court has upheld the permanent disqualification from wage replacement benefits of a workers’...

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence
Feb 18, 2025

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits

In an unpublished decision, a Kansas appellate court has struck down an employer’s attempt to deny workers’ compensation benefits to an employee who refused a drug test 18 days after...

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits
Feb 14, 2025

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim

In Matter of Tudor v. Whitehall Cent. Sch. Dist., 2025 N.Y. App. Div. LEXIS 827 (3d Dept., Feb. 13, 2025), the New York Appellate Division, Third Department, affirmed the state...

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim
Feb 13, 2025

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)

Background On May 21, 1946, Kelly fell and injured his left knee in an accident which arose out of and in the course of his employment with the employer. He...

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949) Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)

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Feb 20, 2025

Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job

Background In 1928, the Minnesota Supreme Court issued a decision that would help establish important principles about when off-premises lunch injuries fall within the scope of workers’ compensation coverage. The...

Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job
Feb 19, 2025

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence

In a decision that reinforces the potential consequences of misrepresenting one’s physical condition, a New York appellate court has upheld the permanent disqualification from wage replacement benefits of a workers’...

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence
Feb 18, 2025

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits

In an unpublished decision, a Kansas appellate court has struck down an employer’s attempt to deny workers’ compensation benefits to an employee who refused a drug test 18 days after...

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits
Feb 14, 2025

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim

In Matter of Tudor v. Whitehall Cent. Sch. Dist., 2025 N.Y. App. Div. LEXIS 827 (3d Dept., Feb. 13, 2025), the New York Appellate Division, Third Department, affirmed the state...

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim
Feb 13, 2025

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)

Background On May 21, 1946, Kelly fell and injured his left knee in an accident which arose out of and in the course of his employment with the employer. He...

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949) Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)
Feb 10, 2025

Florida Workers’ Comp Lien Includes Post-Settlement Benefits

A Florida appellate court has ruled that a workers’ compensation carrier’s statutory lien rights extend to all benefits paid through the date of equitable distribution, not merely those paid through...

Florida Workers’ Comp Lien Includes Post-Settlement Benefits Florida Workers’ Comp Lien Includes Post-Settlement Benefits
Feb 7, 2025

SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute

In Russell v. Wal-Mart Stores, Inc., 2025 S.C. LEXIS 13 (Jan. 29, 2025), the South Carolina Supreme Court reversed a Workers’ Compensation Commission ruling that denied an injured worker additional...

SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute
Feb 6, 2025

Throwback Thursday: Bailey v. American General Ins. Co. (1955)

The Case and Its Context The 1955 Texas Supreme Court decision in Bailey v. American General Insurance Co., 154 Tex. 430, 279 S.W.2d 315 (1955), represents a landmark in the...

Throwback Thursday: Bailey v. American General Ins. Co. (1955) Throwback Thursday: Bailey v. American General Ins. Co. (1955)
Feb 4, 2025

Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable

In a case of first impression, an Illinois appellate court has held that work-related pain alone—without accompanying structural change or worsening—can constitute a compensable aggravation of a pre-existing asymptomatic condition...

Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable
Feb 3, 2025

GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns

A Georgia appellate court recently reversed a state Workers’ Compensation Board decision that denied temporary total disability (TTD) benefits to an employee who refused light-duty work due to COVID-19 health...

GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns
Jan 30, 2025

Throwback Thursday: Whetro v. Awkerman (1970)

When Mother Nature Met Workers’ Compensation On Palm Sunday 1965, a devastating series of tornadoes tore through southern Michigan. Among the victims were two workers: Carl Whetro, injured when the...

Throwback Thursday: Whetro v. Awkerman (1970) Throwback Thursday: Whetro v. Awkerman (1970)
Jan 28, 2025

“Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer

An Ohio employer cannot be held liable under the doctrine of respondeat superior for an employee’s negligent driving during a commute to work, even where the employee might reasonably be...

“Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer “Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer

New Comments

  • trob: Excellent question. My thought is that the employer was following what it assumed was the typical practice of seeking to protect its "subrogation" interest in state court; in virtually all jurisdictions, the state trial courts are where subrogation issues are litigated. What differed here, of course, was that it wasn't a standard subrogation case, i.e., the employee's work-related injury wasn't ca...
  • ramivou: Why didn't they file it with the state Commission instead?
  • Thomas A. Robinson: I suspect that ACME could seek contractual indemnity, as you note, either from the staffing agency or its carrier. The goal of the Board or agency generally is to see to the proper award of benefits for compensable injuries. Allowing the "aggrieved" parties to sort it out later is completely consistent with the overall theory of workers' compensation. Many thanks for the comment. Best wishes.
  • Barry Stinson: I wonder if Acme's insurer could seek contractural indemnity from Variety's insurer outside of the WC system.
  • Michael C. Duff: The conceptual distinction is between joint causation and presumptive single causation.
  • Thomas A. Robinson: Sorry, I don't/can't provide legal advice. Best wishes, however.
  • Ken Smith: What can I do when my attorney blows my case with an incomplete RB89
  • Thomas A. Robinson: Good point, although the interesting thing about the case--at least to me--is that it discusses the important "injury by accident" issue. That issue, present in at least a plurality of state acts, is largely ignored by Commissions, Boards, and Courts these days. Here, also, the case was so fact-specific that even it had been issued as published, it would be factually distinguishable from many othe...
  • kathlyn gorman: It should have been noted in your discussion that this is an unpublished opinion of the North Carolina Court of Appeals. Thus, it does not constitute controlling legal authority.
  • Thomas A. Robinson: You're correct. Ordinarily, I can depend upon Alabama to provide me with at least one case for "the List." I'll bet 2022 will unearth something bizarre from the Great State of Alabama. Take care.