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Dec 2, 2024

Oregon Court Affirms Award Where Elderly Worker Fainted For Unknown Reason

The Oregon Court of Appeals recently affirmed a Workers’ Compensation Board decision awarding benefits to an 85-year-old worker who fainted while waiting for an employer-mandated vaccination [SAIF Corp. v. Kelkay,...

Oregon Court Affirms Award Where Elderly Worker Fainted For Unknown Reason Oregon Court Affirms Award Where Elderly Worker Fainted For Unknown Reason
Nov 25, 2024

Hawaii: Defamation Claims Against Employer Not Barred by Workers’ Compensation Exclusivity

The Intermediate Court of Appeals of Hawai’i recently held that while an employee’s negligent supervision claim against his employer was barred by workers’ compensation exclusivity, he should have been given...

Hawaii: Defamation Claims Against Employer Not Barred by Workers’ Compensation Exclusivity Hawaii: Defamation Claims Against Employer Not Barred by Workers’ Compensation Exclusivity
Nov 21, 2024

Divided PA Court Says “Continuous Service,” Not Level of Activity, Key to Firefighter Cancer Benefits

In Borough of Hollidaysburg v. Detwiler, 2024 Pa. Commw. LEXIS 243 (Nov. 19, 2024), a divided Commonwealth Court of Pennsylvania held that to enjoy the state’s presumption of compensability, volunteer...

Divided PA Court Says “Continuous Service,” Not Level of Activity, Key to Firefighter Cancer Benefits Divided PA Court Says “Continuous Service,” Not Level of Activity, Key to Firefighter Cancer Benefits
Nov 20, 2024

NY Court Affirms Board’s Rejection of Medical Opinion Based on Flawed Work History

In a decision highlighting the importance of accurate work histories in medical causation opinions, a New York appellate court has upheld the Workers’ Compensation Board’s denial of death benefits in...

NY Court Affirms Board’s Rejection of Medical Opinion Based on Flawed Work History NY Court Affirms Board’s Rejection of Medical Opinion Based on Flawed Work History

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Jun 30, 2012

Arkansas: Only Partial Offset of Claimant’s Disability Benefits By Retirement Benefits Allowed

Workers’ compensation, unemployment compensation, nonoccupational sickness and disability insurance, and old age and survivors’ and disability insurance are all based upon a common principle and a common operative fact: wage...

Arkansas: Only Partial Offset of Claimant’s Disability Benefits By Retirement Benefits Allowed Arkansas: Only Partial Offset of Claimant’s Disability Benefits By Retirement Benefits Allowed
Jun 29, 2012

Oregon: Police Lieutenant’s Injuries During Coffee Break Are Compensable

On Wednesday, the Court of Appeals of Oregon, in McDermed v. City of Eugene, 2012 Ore. App. LEXIS 796 (June 27, 2012), affirmed an award of workers’ compensation benefits to...

Oregon: Police Lieutenant’s Injuries During Coffee Break Are Compensable Oregon: Police Lieutenant’s Injuries During Coffee Break Are Compensable
Jun 21, 2012

Ohio: Unpaid Work for Wife’s Business Warranted Forfeiture of Benefits, But Not Finding of Fraudulent Activity

The Supreme Court of Ohio, affirming a decision of a lower level appellate court, recently held that while a claimant could not receive temporary total disability (TTD) benefits for any...

Ohio: Unpaid Work for Wife’s Business Warranted Forfeiture of Benefits, But Not Finding of Fraudulent Activity Ohio: Unpaid Work for Wife’s Business Warranted Forfeiture of Benefits, But Not Finding of Fraudulent Activity
Jun 16, 2012

Missouri: Survivors May Proceed in Tort Against Uninsured Employer After Recovering Workers’ Compensation Benefits From Statutory Employer–No Election of Remedies Problem

In a 4–3 decision, the Supreme Court of Missouri recently reversed the decision of a state trial court that earlier had held a workers’ compensation award against a statutory employer...

Missouri: Survivors May Proceed in Tort Against Uninsured Employer After Recovering Workers’ Compensation Benefits From Statutory Employer–No Election of Remedies Problem Missouri: Survivors May Proceed in Tort Against Uninsured Employer After Recovering Workers’ Compensation Benefits From Statutory Employer–No Election of Remedies Problem
Jun 15, 2012

Virginia: Non-Dependent Relative of Deceased Worker Caught in Catch-22

In the vast majority of states, non-dependent relatives of employees who suffer fatal work-related injuries are caught in a Catch-22. Since most state acts limit workers’ compensation death benefits to...

Virginia: Non-Dependent Relative of Deceased Worker Caught in Catch-22 Virginia: Non-Dependent Relative of Deceased Worker Caught in Catch-22
Jun 8, 2012

Maryland: Supervisor May Be Sued By Co-Employee re: Parking Lot Vehicular Accident

All but four states (Arkansas, Missouri, Maryland, Vermont, plus the Virgin Islands) extend immunity from tort liability not only to the employer, but co-employees, at least as long as the...

Maryland: Supervisor May Be Sued By Co-Employee re: Parking Lot Vehicular Accident Maryland: Supervisor May Be Sued By Co-Employee re: Parking Lot Vehicular Accident
Jun 6, 2012

US: 2010 Statutory Amendment Spelled “Certain” Demise of Oklahoma’s “Substantially Certain” Rule in Intentional Injury Actions Against Employers

An important exception to the exclusive remedy rule relates to intentional injury inflicted by the employer on an employee. Several legal theories have been advanced to support the exception. The...

US: 2010 Statutory Amendment Spelled “Certain” Demise of Oklahoma’s “Substantially Certain” Rule in Intentional Injury Actions Against Employers US: 2010 Statutory Amendment Spelled “Certain” Demise of Oklahoma’s “Substantially Certain” Rule in Intentional Injury Actions Against Employers
May 31, 2012

Missouri: Divided Supreme Court Reverses Award of Benefits to Employee Injured Making Coffee for Herself and Others in the Office Kitchen

The Supreme Court of Missouri, in a split decision, construing the state’s version of the “increased-risk” doctrine, on Tuesday (May 29) reversed an award of workers’ compensation benefits to an...

Missouri: Divided Supreme Court Reverses Award of Benefits to Employee Injured Making Coffee for Herself and Others in the Office Kitchen Missouri: Divided Supreme Court Reverses Award of Benefits to Employee Injured Making Coffee for Herself and Others in the Office Kitchen
May 29, 2012

Virginia: Claimant Awarded Post-Termination PD Benefits; Her Poor Performance Was In Part Tied to Her Compensable Injuries

As noted by Larson’s Workers’ Compensation Law, § 84.02 et seq., some of the most complex disability questions arise when the claimant returns to some kind of employment after the...

Virginia: Claimant Awarded Post-Termination PD Benefits; Her Poor Performance Was In Part Tied to Her Compensable Injuries Virginia: Claimant Awarded Post-Termination PD Benefits; Her Poor Performance Was In Part Tied to Her Compensable Injuries
May 25, 2012

Kentucky: Stable Groom, Injured In Auto Accident Returning to Kentucky From New York, Was “Traveling Employee” In Spite of Indefinite Nature of Travel Details

A stable groom for a horse farm, who sustained multiple injuries in an automobile accident that occurred while he rode with a friend back to Kentucky from Saratoga, New York,...

Kentucky: Stable Groom, Injured In Auto Accident Returning to Kentucky From New York, Was “Traveling Employee” In Spite of Indefinite Nature of Travel Details Kentucky: Stable Groom, Injured In Auto Accident Returning to Kentucky From New York, Was “Traveling Employee” In Spite of Indefinite Nature of Travel Details
May 24, 2012

Illinois: Safety Inspectors Are Immune From Tort Liability For Negligent Inspection

An integral and important part of the workers’ compensation “bargain” is the notion that once a workers’ compensation act has become applicable, either through compulsion or election, it affords the...

Illinois: Safety Inspectors Are Immune From Tort Liability For Negligent Inspection Illinois: Safety Inspectors Are Immune From Tort Liability For Negligent Inspection
May 11, 2012

Texas Widow Prevails In Death Claim Case By Showing Husband’s Drug Overdose Could Have Been Caused By Side Effects of Prescription Pain Medication

It is axiomatic in workers’ compensation law that a subsequent injury, whether an aggravation of the original injury or a new and distinct injury, is compensable if it is the...

Texas Widow Prevails In Death Claim Case By Showing Husband’s Drug Overdose Could Have Been Caused By Side Effects of Prescription Pain Medication Texas Widow Prevails In Death Claim Case By Showing Husband’s Drug Overdose Could Have Been Caused By Side Effects of Prescription Pain Medication

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.