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Jan 6, 2025

Iowa Court Affirms Denial of Benefits re: COVID-19 Claim

In Collins v. Des Moines Area Regional Transit Authority (DART), 2024 Iowa App. LEXIS 918 (Dec. 18, 2024), the Iowa Court of Appeals affirmed denial of workers’ compensation benefits to...

Iowa Court Affirms Denial of Benefits re: COVID-19 Claim Iowa Court Affirms Denial of Benefits re: COVID-19 Claim
Jan 6, 2025

Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence

In Spisa-Kline v. Mary Lanning Memorial Hospital, 2024 Neb. App. LEXIS 750 (Dec. 31, 2024), the Nebraska Court of Appeals affirmed summary judgment for the employer in a workers’ compensation...

Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence
Dec 31, 2024

Oregon Jaywalker Might Be Awarded Benefits

Appeals Court Examines Going and Coming Rule The Oregon Court of Appeals has reversed and remanded a Workers’ Compensation Board decision that had denied benefits to a worker injured while...

Oregon Jaywalker Might Be Awarded Benefits Oregon Jaywalker Might Be Awarded Benefits
Dec 30, 2024

NC Court of Appeals Reverses $28.9 Million Tort Judgment

Insurer Had No Duty to Defend Intentional Tort Claim Against Co-Employee In Ortez v. Penn Nat’l Sec. Ins. Co., 2024 N.C. App. LEXIS 1017 (Dec. 17, 2024), the North Carolina...

NC Court of Appeals Reverses $28.9 Million Tort Judgment NC Court of Appeals Reverses $28.9 Million Tort Judgment

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Dec 20, 2012

Florida: Truck Driver Is Employed During Two-Day “Orientation” and is Entitled To Workers’ Compensation Benefits

A truck driver, who sustained injuries in an automobile accident as he traveled to lunch on the second day of a two-day orientation program was an employee of the trucking...

Florida: Truck Driver Is Employed During Two-Day “Orientation” and is Entitled To Workers’ Compensation Benefits Florida: Truck Driver Is Employed During Two-Day “Orientation” and is Entitled To Workers’ Compensation Benefits
Dec 19, 2012

Kentucky: Teacher’s Tort Action Against Snake-Handling Assistant Principal Barred by Exclusivity

The Court of Appeals of Kentucky recently affirmed a state trial court’s summary judgment in favor of a high school assistant principal and a county board of education in a...

Kentucky: Teacher’s Tort Action Against Snake-Handling Assistant Principal Barred by Exclusivity Kentucky: Teacher’s Tort Action Against Snake-Handling Assistant Principal Barred by Exclusivity
Dec 16, 2012

US: Office Worker’s Tort Action Against Dentist Employer Alleging Sexual Assault Not Barred by Exclusivity

In Painter v. Atwood, 2012 U.S. Dist. LEXIS 176655 (D. Nev., Dec. 12, 2012), a federal district court from Nevada recently held, in relevant part, that a civil action filed...

US: Office Worker’s Tort Action Against Dentist Employer Alleging Sexual Assault Not Barred by Exclusivity US: Office Worker’s Tort Action Against Dentist Employer Alleging Sexual Assault Not Barred by Exclusivity
Dec 5, 2012

Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative

Reversing the state’s Court of Appeals, the Supreme Court of Georgia has ruled that an employee who filed a claim under the state’s Workers’ Compensation Act, must authorize her treating...

Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative
Nov 23, 2012

Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded

An Arizona appellate court recently held, as a matter of law, that a workers’ compensation claimant who expressed an intention to record an independent medical examination (“IME”), in the absence...

Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded
Nov 21, 2012

LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell

Under the Longshore and Harbor Workers’ Compensation Act (“LHWCA”), no compensation is payable “if the injury was occasioned solely by the intoxication of the employee” [see 33 U.S.C. § 903(c)]....

LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell
Nov 19, 2012

Getting Hurt “On the Job”

As I’ve mentioned in my last several posts, a bit more than a week ago, I enjoyed being part of three panel discussions at the 21st Annual National Workers’ Compensation...

Getting Hurt “On the Job” Getting Hurt “On the Job”
Nov 16, 2012

Oklahoma: Supreme Court Reverses Court of Appeals in “Substantially Certain” Case

In what will likely be one of the last cases to be heard under Oklahoma’s court-crafted version of the “substantially certain” rule [see Larson’s Workers’ Compensation Law, § 103.04[2][e]] that...

Oklahoma: Supreme Court Reverses Court of Appeals in “Substantially Certain” Case Oklahoma: Supreme Court Reverses Court of Appeals in “Substantially Certain” Case
Nov 15, 2012

Indiana: Recent Decision Shows the General Strength of the Exclusivity Defense

Last week, at the 21st Annual National Workers’ Compensation and Disability Conference® & Expo, in Las Vegas, I was happy to be part of a panel discussion regarding the “Future...

Indiana: Recent Decision Shows the General Strength of the Exclusivity Defense Indiana: Recent Decision Shows the General Strength of the Exclusivity Defense
Nov 14, 2012

New York: Failure to Disclose Injury in Professional Boxing Match Causes Forfeiture of Future Disability Rights

A New York appellate court, in Martinez v. Lefrak City Mngmt., 2012 N.Y. App. Div. LEXIS 7330 (3rd Dept., Nov. 8, 2012), recently affirmed a finding by the state’s Workers’...

New York: Failure to Disclose Injury in Professional Boxing Match Causes Forfeiture of Future Disability Rights New York: Failure to Disclose Injury in Professional Boxing Match Causes Forfeiture of Future Disability Rights
Nov 9, 2012

Live From Las Vegas!

4:30 PM (Pacific) I’m sorry that it’s been a couple of weeks since my last post. It isn’t that my mind has been on matters other than workers’ compensation. In...

Live From Las Vegas! Live From Las Vegas!
Oct 24, 2012

New York: Extraordinary Duties at Grocery Store on Super Bowl Sunday Mean Employee’s Death is Compensable

A New York appellate court recently agreed with the state’s Workers’ Compensation Board that the death of a grocery store employee was causally related to the employment where evidence showed...

New York: Extraordinary Duties at Grocery Store on Super Bowl Sunday Mean Employee’s Death is Compensable New York: Extraordinary Duties at Grocery Store on Super Bowl Sunday Mean Employee’s Death is Compensable

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.