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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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Oct 23, 2012

Iowa: Court Approves “Uneven” Split of Death Benefits Between American and Honduran Dependents of Deceased Undocumented Worker

The Court of Appeals of Iowa, in Carter v. Alter Trading Corp., 2012 Iowa App. LEXIS 879 (Oct. 17, 2012), applying the state’s “equitable” apportionment of workers’ compensation death benefits...

Iowa: Court Approves “Uneven” Split of Death Benefits Between American and Honduran Dependents of Deceased Undocumented Worker Iowa: Court Approves “Uneven” Split of Death Benefits Between American and Honduran Dependents of Deceased Undocumented Worker
Oct 20, 2012

Iowa: Court Finds Evidence Does Not Support Requiring Employer to Bear Expense of Gastric Bypass Surgery

Because an injured worker offered no evidence, other than her own testimony, that her gastric bypass surgery had been beneficial to her work-related injury, it was error to find the...

Iowa: Court Finds Evidence Does Not Support Requiring Employer to Bear Expense of Gastric Bypass Surgery Iowa: Court Finds Evidence Does Not Support Requiring Employer to Bear Expense of Gastric Bypass Surgery
Oct 19, 2012

Illinois: Injured Employee’s “Dual Capacity/Dual Persona” Claim Against Corporate Officers of Employer Fails

In a recent decision by the Appellate Court of Illinois, Second District, Hilgart v. 210 Mittel Drive Partnership, 2012 Ill. App. LEXIS 850 (Oct. 17, 2012), the court held that...

Illinois: Injured Employee’s “Dual Capacity/Dual Persona” Claim Against Corporate Officers of Employer Fails Illinois: Injured Employee’s “Dual Capacity/Dual Persona” Claim Against Corporate Officers of Employer Fails
Oct 18, 2012

Florida: “Firefighter’s Presumption” Aids Corrections Officer’s Heart Disease Claim Related to Unknown Virus Infection

Construing Florida’s “Firefighter’s Presumption” [see § 112.18(1), Fla. Stat.], in Walters v. State, 2012 Fla. App. LEXIS 17887 (1st Dist., Oct. 16, 2012), a state appellate court recently reversed a...

Florida: “Firefighter’s Presumption” Aids Corrections Officer’s Heart Disease Claim Related to Unknown Virus Infection Florida: “Firefighter’s Presumption” Aids Corrections Officer’s Heart Disease Claim Related to Unknown Virus Infection
Oct 16, 2012

US: Injured Employee May Not Sue Insured Iowa Employer For Bad Faith Failure to Pay Workers’ Comp Claim

A federal district court, sitting in Iowa, recently granted an employer’s motion to dismiss an action filed against it by a worker who had asserted that he had been injured...

US: Injured Employee May Not Sue Insured Iowa Employer For Bad Faith Failure to Pay Workers’ Comp Claim US: Injured Employee May Not Sue Insured Iowa Employer For Bad Faith Failure to Pay Workers’ Comp Claim
Oct 15, 2012

Pennsylvania: Injured Worker’s Participation in Employer’s “Special Attrition Plan” Causes a Loss in Disability Benefits

Evidence that an injured worker attended his employer’s “Attrition Plan” meeting and signed forms related to the employer’s “Special Attrition Plan,” that provided for, among other things, a lump sum...

Pennsylvania: Injured Worker’s Participation in Employer’s “Special Attrition Plan” Causes a Loss in Disability Benefits Pennsylvania: Injured Worker’s Participation in Employer’s “Special Attrition Plan” Causes a Loss in Disability Benefits
Oct 8, 2012

Iowa: Lack of “Adequate” Remedy Does Not Mean Exclusive Remedy Provision May Be Circumvented

As observed by Dr. Larson, the exclusiveness defense is part of the quid pro quo by which “the sacrifices and gains of employees and employers are to some extent put...

Iowa: Lack of “Adequate” Remedy Does Not Mean Exclusive Remedy Provision May Be Circumvented Iowa: Lack of “Adequate” Remedy Does Not Mean Exclusive Remedy Provision May Be Circumvented
Oct 3, 2012

New York: By Hiring Illegal Alien, Employer Did Not Give Up Protection Against Third-Party Claims for Contribution and/or Indemnification

In spite of the fact that the Federal Immigration Reform and Control Act of 1986 (IRCA) makes it unlawful to knowingly hire undocumented (illegal) aliens [see 8 U.S.C.S. § 1324a],...

New York: By Hiring Illegal Alien, Employer Did Not Give Up Protection Against Third-Party Claims for Contribution and/or Indemnification New York: By Hiring Illegal Alien, Employer Did Not Give Up Protection Against Third-Party Claims for Contribution and/or Indemnification
Oct 2, 2012

New York: Comp Carrier Entitled to Take Credit Against Future Benefits for Rape Victim’s Settlement Against Employer and Co-Employees

A workers’ compensation carrier, who paid benefits to an aide at a juvenile detention center who was physically assaulted, raped, and kidnapped is entitled to take a dollar-for-dollar credit against...

New York: Comp Carrier Entitled to Take Credit Against Future Benefits for Rape Victim’s Settlement Against Employer and Co-Employees New York: Comp Carrier Entitled to Take Credit Against Future Benefits for Rape Victim’s Settlement Against Employer and Co-Employees
Sep 27, 2012

Kentucky: Electric Cooperative Shielded From Tort Action Filed by Dependents of Deceased Employee of Subcontractor–The Fact That Ice Storm Overwhelmed Resources of Coop Did Not Mean Repair Work Was Not Part of Coop’s “Normal” Business

All but a handful of states have “statutory-employer” or “contractor-under” provisions within their workers’ compensation laws that make a general contractor liable for compensation to the employee of a subcontractor–usually...

Kentucky: Electric Cooperative Shielded From Tort Action Filed by Dependents of Deceased Employee of Subcontractor–The Fact That Ice Storm Overwhelmed Resources of Coop Did Not Mean Repair Work Was Not Part of Coop’s “Normal” Business Kentucky: Electric Cooperative Shielded From Tort Action Filed by Dependents of Deceased Employee of Subcontractor–The Fact That Ice Storm Overwhelmed Resources of Coop Did Not Mean Repair Work Was Not Part of Coop’s “Normal” Business
Sep 25, 2012

South Carolina: Injured Crane Operator’s Confident Testimony that He Could Run a Restaurant Did Not Constitute Substantial Evidence That He Had Not Proved Wage Loss

Testimony by an injured crane operator that he was interested in opening a restaurant was too speculative to support the full commission’s finding that the crane operator had not proved...

South Carolina: Injured Crane Operator’s Confident Testimony that He Could Run a Restaurant Did Not Constitute Substantial Evidence That He Had Not Proved Wage Loss South Carolina: Injured Crane Operator’s Confident Testimony that He Could Run a Restaurant Did Not Constitute Substantial Evidence That He Had Not Proved Wage Loss
Sep 24, 2012

Ohio: Total Loss of Use of Rotator Cuff Does Not Mean Loss of Use of Arm

In Ohio, with the exceptions of hearing and sight, scheduled loss compensation was originally limited to amputation. More recently, however, (see State ex rel. Kroger Co. v. Johnson, 128 Ohio...

Ohio: Total Loss of Use of Rotator Cuff Does Not Mean Loss of Use of Arm Ohio: Total Loss of Use of Rotator Cuff Does Not Mean Loss of Use of Arm

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.