Newest Articles

May 8, 2025

Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948)

Imported Quarrels and the Boundaries of Employment Risk In Bridges v. Elite, Inc., 212 S.C. 514, 48 S.E.2d 497 (S.C. 1948), the Supreme Court of South Carolina reversed a decision...

Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948) Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948)
May 7, 2025

NY Court Clarifies When Financial Hardship Justifies Total Disability

Construing an exception to New York’s cap on permanent partial disability (PPD) benefits [see N.Y. Workers’ Comp. Law, § 35(3)], which allows—in certain situations—reclassification of the claimant’s disability to permanent...

NY Court Clarifies When Financial Hardship Justifies Total Disability NY Court Clarifies When Financial Hardship Justifies Total Disability
May 6, 2025

California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute

In a decision reemphasizing the boundaries of compensability for commuting injuries, the California Court of Appeal (Third Appellate District) has annulled a WCAB award awarding workers’ compensation benefits to a...

California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute
May 1, 2025

Throwback Thursday: Martin v. Industrial Accident Commission (1956)

Refusal of Life-Saving Treatment Within Workers’ Compensation Context In Martin v. Industrial Accident Commission, 147 Cal. App. 2d 137, 304 P.2d 828 (Cal. Ct. App. 1956), the California Court of...

Throwback Thursday: Martin v. Industrial Accident Commission (1956) Throwback Thursday: Martin v. Industrial Accident Commission (1956)

All Articles

ARCHIVE
2025
2024
2023
2022
2021
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
May 12, 2025

Final Means Final—Even When the Law Changes

Favorable Ruling by NY High Court Cannot Support Employer’s Reopening Request In Matter of Coyle v. W & W Steel Erectors LLC, 2025 N.Y. App. Div. LEXIS 2889 (3d Dept....

Final Means Final—Even When the Law Changes Final Means Final—Even When the Law Changes
May 8, 2025

Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948)

Imported Quarrels and the Boundaries of Employment Risk In Bridges v. Elite, Inc., 212 S.C. 514, 48 S.E.2d 497 (S.C. 1948), the Supreme Court of South Carolina reversed a decision...

Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948) Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948)
May 7, 2025

NY Court Clarifies When Financial Hardship Justifies Total Disability

Construing an exception to New York’s cap on permanent partial disability (PPD) benefits [see N.Y. Workers’ Comp. Law, § 35(3)], which allows—in certain situations—reclassification of the claimant’s disability to permanent...

NY Court Clarifies When Financial Hardship Justifies Total Disability NY Court Clarifies When Financial Hardship Justifies Total Disability
May 6, 2025

California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute

In a decision reemphasizing the boundaries of compensability for commuting injuries, the California Court of Appeal (Third Appellate District) has annulled a WCAB award awarding workers’ compensation benefits to a...

California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute
May 1, 2025

Throwback Thursday: Martin v. Industrial Accident Commission (1956)

Refusal of Life-Saving Treatment Within Workers’ Compensation Context In Martin v. Industrial Accident Commission, 147 Cal. App. 2d 137, 304 P.2d 828 (Cal. Ct. App. 1956), the California Court of...

Throwback Thursday: Martin v. Industrial Accident Commission (1956) Throwback Thursday: Martin v. Industrial Accident Commission (1956)
Apr 30, 2025

Arkansas Court Enforces Strict Dependency Hierarchy Despite Estrangement

In a decision underscoring the rigid statutory structure governing death benefits in workers’ compensation law, the Arkansas Court of Appeals recently affirmed the denial of benefits to the parents of...

Arkansas Court Enforces Strict Dependency Hierarchy Despite Estrangement Arkansas Court Enforces Strict Dependency Hierarchy Despite Estrangement
Apr 29, 2025

Georgia Court Blocks Assigned Negligence Claim Over Lapsed Workers’ Compensation Coverage

In Diaz Arriola v. Coleman, 2025 Ga. App. LEXIS 161 (Apr. 24, 2025), the Georgia Court of Appeals affirmed the dismissal of an injured employee’s assigned negligence and breach of...

Georgia Court Blocks Assigned Negligence Claim Over Lapsed Workers’ Compensation Coverage Georgia Court Blocks Assigned Negligence Claim Over Lapsed Workers’ Compensation Coverage
Apr 28, 2025

Hawaii Supreme Court Clarifies Employee Status in Workers’ Compensation Context

The Hawai’i Supreme Court recently held that a tenant who performed maintenance work on rental property, in exchange for reduced rent and occasional payment, was an employee—not a volunteer—and accordingly...

Hawaii Supreme Court Clarifies Employee Status in Workers’ Compensation Context Hawaii Supreme Court Clarifies Employee Status in Workers’ Compensation Context
Apr 24, 2025

Throwback Thursday: Lee v. Minneapolis Street Railway Co. (1950)

The Rise of the Odd-Lot Doctrine In the world of workers’ compensation, some of the most influential doctrines arise not from statutory overhaul or regulatory edict, but from judicial insight...

Throwback Thursday: Lee v. Minneapolis Street Railway Co. (1950) Throwback Thursday: Lee v. Minneapolis Street Railway Co. (1950)
Apr 22, 2025

SD Supreme Court Weighs Conflicting Medical Evidence

Reverses Factual Findings Where Evidence Was in Deposition Form In a split decision, the South Dakota Supreme Court reversed—in relevant part—a Department of Labor determination that had ruled a claimant’s...

SD Supreme Court Weighs Conflicting Medical Evidence SD Supreme Court Weighs Conflicting Medical Evidence
Apr 21, 2025

MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases

In a thoughtful and clarifying opinion, the Minnesota Supreme Court has reaffirmed the case-specific nature of the statutory retirement presumption applicable to permanent total disability (PTD) claims under Minn. Stat....

MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases
Apr 17, 2025

Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951)

Introduction In 1951, the U.S. Supreme Court handed down its decision in O’Leary v. Brown-Pacific-Maxon, Inc., 340 U.S. 504, 71 S.Ct. 470, 95 L.Ed.483 (1951). The case involved a claim...

Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951) Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951)

New Comments

  • trob: Thanks for the query. New York's going and coming doctrine is similar to that in place in the majority of jurisdictions. That is to say that for employees with a fixed place of work and who are on a relatively consistent work schedule, the commute to and from the residence is outside the course and scope of the employment. Often overlooked is the fact that the employee must generally have a fixed ...
  • ramivou: Is coming and going covered in NY?
  • 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...