Newest Articles

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)
Apr 15, 2025

Arkansas Court Denies Benefits to Good Samaritan Band Director

In a ruling that reaffirms Arkansas’ strict interpretation of its “employment services” requirement, the state’s Court of Appeals recently affirmed a Workers’ Compensation Commission decision denying benefits to the family...

Arkansas Court Denies Benefits to Good Samaritan Band Director Arkansas Court Denies Benefits to Good Samaritan Band Director
Apr 14, 2025

Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack

In a decision that further defines the barriers to pursuing civil remedies in workplace injury cases within the Louisiana, a state appellant court recently affirmed summary a trial court judgment...

Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack
Apr 10, 2025

Throwback Thursday: Hawk v. Jim Hawk Chevrolet-Buick, Inc., 282 N.W.2d 84 (Iowa 1979)

Background On September 28, 1973, at approximately 2:30 a.m., James Hawk II, the president, sole stockholder, and chief operating officer of Jim Hawk Chevrolet-Buick, Inc., died when his private airplane...

Throwback Thursday: Hawk v. Jim Hawk Chevrolet-Buick, Inc., 282 N.W.2d 84 (Iowa 1979) Throwback Thursday: Hawk v. Jim Hawk Chevrolet-Buick, Inc., 282 N.W.2d 84 (Iowa 1979)

All Articles

ARCHIVE
2025
2024
2023
2022
2021
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
Sep 29, 2013

Employers Face Possible Liability in “Pretaliatory” Discharge Cases

The great majority of jurisdictions that have dealt with the issue, either by decision or statute, recognize the tort of retaliatory discharge for filing a workers compensation claim [see Larson’s...

Employers Face Possible Liability in “Pretaliatory” Discharge Cases Employers Face Possible Liability in “Pretaliatory” Discharge Cases
Sep 27, 2013

CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court

In a decision officially to be released on Tuesday (October 1), the Supreme Court of Connecticut has affirmed a decision of the state’s Workers’ Compensation Review Board that in turn...

CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court
Sep 27, 2013

6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola

A divided en banc panel of the Sixth Circuit Court of Appeals has reversed a decision by a three-judge panel of the same Circuit Court that had allowed a RICO...

6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola 6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola
Sep 19, 2013

Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails

Extensively quoting from Larson’s Workers’ Compensation Law and reiterating the state’s two-prong test to invoke the so-called “dual capacity doctrine” as an exception to the exclusive remedy provided by the...

Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails
Sep 18, 2013

Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000

In Ohio, like most jurisdictions, an employer or carrier that provides an injured worker with workers’ compensation benefits enjoys a subrogation interest, to the extent of such payment, in any...

Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000 Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000
Sep 14, 2013

Illinois: Workers’ Comp’s “Traveling Employee” Rule May Not Be Expanded to Tort Arena

Under workers’ compensation law’s so-called “going and coming” rule, for an employee having fixed hours and place of work, injuries sustained en route to or from the workplace are generally...

Illinois: Workers’ Comp’s “Traveling Employee” Rule May Not Be Expanded to Tort Arena Illinois: Workers’ Comp’s “Traveling Employee” Rule May Not Be Expanded to Tort Arena
Sep 9, 2013

Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee

In the determination of any contested workers’ compensation claim, Hawaii favors the claimant with a presumption of compensability [HRS § 386–85]. Construing that presumption, a state appellate court recently affirmed...

Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee
Sep 7, 2013

Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable

Illustrating the significant deference given to the Commission’s factual findings, an Arkansas appellate court recently affirmed the denial of benefits to an employee who sustained injuries when he slipped and...

Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable
Sep 4, 2013

Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits

In many states, the death benefit owed to a surviving spouse is commuted, sometimes at a significant discount, if the surviving spouse remarries. The Missouri statute, § 287.240(4)(a) R.S. Mo.,...

Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits
Aug 30, 2013

Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason

An Oregon appellate court recently affirmed a decision by the state’s Workers’ Compensation Board that concluded claimant’s subsistence and travel pay were “wages” for purposes of determining claimant’s TTD benefits...

Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason
Aug 30, 2013

New Hampshire: Intoxication, Without Showing of Causation, Is Insufficient to Defeat Comp Claim

Reiterating an important point, that in order to defeat a workers’ compensation claim it is generally insufficient to show that the injured worker was intoxicated at the time of the...

New Hampshire: Intoxication, Without Showing of Causation, Is Insufficient to Defeat Comp Claim New Hampshire: Intoxication, Without Showing of Causation, Is Insufficient to Defeat Comp Claim
Aug 27, 2013

Texas: No Arbitration Where Employer Could Not Show Employee Had Notice of Arbitration Agreement

Notice of the Texas non-subscribing employer’s occupational injury benefit plan was insufficient by itself to show that an employee had notice of an arbitration agreement referred to therein since the...

Texas: No Arbitration Where Employer Could Not Show Employee Had Notice of Arbitration Agreement Texas: No Arbitration Where Employer Could Not Show Employee Had Notice of Arbitration Agreement

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...