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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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May 8, 2012

Oklahoma Opt Out Legislation Fails: A Post Mortem

By Thomas A. Robinson Late last Wednesday evening (April 25th), supporters of a controversial bill that would have allowed some Oklahoma employers to “opt out” of the state’s traditional workers’...

Oklahoma Opt Out Legislation Fails: A Post Mortem Oklahoma Opt Out Legislation Fails: A Post Mortem
Apr 27, 2012

Oklahoma’s Controversial “Opt Out” Legislation Fails (At Least Temporarily)

Late Wednesday evening, supporters of a controversial bill that would allow some Oklahoma employers to “opt out” of the state’s traditional workers’ compensation system [see Oklahoma House Bill 2155] fell...

Oklahoma’s Controversial “Opt Out” Legislation Fails (At Least Temporarily) Oklahoma’s Controversial “Opt Out” Legislation Fails (At Least Temporarily)
Apr 21, 2012

The Fight Against Workers’ Compensation Fraud Takes Many Forms–Florida Goes After Unscrupulous Check Cashing Firms

In August 2007, the Supreme Court of Florida ordered the empanelment of a statewide grand jury to investigate various criminal offenses, including activities related to check cashers. In 2008, the...

The Fight Against Workers’ Compensation Fraud Takes Many Forms–Florida Goes After Unscrupulous Check Cashing Firms The Fight Against Workers’ Compensation Fraud Takes Many Forms–Florida Goes After Unscrupulous Check Cashing Firms
Apr 18, 2012

Virginia Court Affirms Denial of Benefits Related to Unexplained Fall In Spite of Evidence That Claimant’s Step From Truck Was Larger Than Normal Staircase Distance

In yesterday’s post, I pointed out the difficulty courts (and not a few practitioners) have had with a specific form of neutral risk–those in which an employee falls while walking...

Virginia Court Affirms Denial of Benefits Related to Unexplained Fall In Spite of Evidence That Claimant’s Step From Truck Was Larger Than Normal Staircase Distance Virginia Court Affirms Denial of Benefits Related to Unexplained Fall In Spite of Evidence That Claimant’s Step From Truck Was Larger Than Normal Staircase Distance
Apr 17, 2012

North Dakota Supreme Court Refuses to Adopt Positional Risk Doctrine in Unexplained Fall Cases

There’s nothing like an employee’s unexplained fall while walking on a level, unobstructed floor to test one’s position on the positional risk doctrine in workers’ compensation claims. As was noted...

North Dakota Supreme Court Refuses to Adopt Positional Risk Doctrine in Unexplained Fall Cases North Dakota Supreme Court Refuses to Adopt Positional Risk Doctrine in Unexplained Fall Cases
Apr 16, 2012

Divided Sixth Circuit Court Delivers Body Blow to Michigan’s Continuing Battle Regarding RICO Claims and Comp Exclusivity

by Thomas A. Robinson A divided Sixth Circuit Court of Appeals, in Brown v. Cassens Transp. Co., 2012 U.S. App. LEXIS 6929 (6th Cir. Apr. 6, 2012), has again reversed...

Divided Sixth Circuit Court Delivers Body Blow to Michigan’s Continuing Battle Regarding RICO Claims and Comp Exclusivity Divided Sixth Circuit Court Delivers Body Blow to Michigan’s Continuing Battle Regarding RICO Claims and Comp Exclusivity
Apr 13, 2012

Ohio: Employer’s Failure to Call Employee Back to Work Was Due to Poor Economy, Not Retaliatory Motive for the Filing of a Comp Claim

An Ohio appellate court, in Lebron v. A&A Safety, Inc., 2012 Ohio 1637, 2012 Ohio App. LEXIS 1435 (Apr. 12, 2012), recently affirmed a trial court’s summary judgment order favoring...

Ohio: Employer’s Failure to Call Employee Back to Work Was Due to Poor Economy, Not Retaliatory Motive for the Filing of a Comp Claim Ohio: Employer’s Failure to Call Employee Back to Work Was Due to Poor Economy, Not Retaliatory Motive for the Filing of a Comp Claim
Apr 6, 2012

Spouse’s “Aggressive Surveillance” Cause of Action May Proceed Against Third-Party Administrator

Generally speaking, the insurance carrier (and any third-party administrator representing the carrier), while performing its proper role in the workers compensation claims process, shares the employer’s immunity to suit by...

Spouse’s “Aggressive Surveillance” Cause of Action May Proceed Against Third-Party Administrator Spouse’s “Aggressive Surveillance” Cause of Action May Proceed Against Third-Party Administrator
Apr 5, 2012

Ohio: Trauma Induced Stroke Sustained In Fall From Wheelchair Is Not Compensable Aggravation of Original Injury

A worker, who lost the use of his legs in 1965 in a work-related accident, and who was thereafter confined to a wheelchair, is not entitled to additional workers compensation...

Ohio: Trauma Induced Stroke Sustained In Fall From Wheelchair Is Not Compensable Aggravation of Original Injury Ohio: Trauma Induced Stroke Sustained In Fall From Wheelchair Is Not Compensable Aggravation of Original Injury
Apr 1, 2012

1st Circuit: “Persistence” On the Part of Injured Employee’s Attorney Results in Attorney Being Sanctioned With Almost $35,000 in Attorney’s Fees

The First Circuit Court of Appeals recently affirmed sanctions in the form of $34,908.12 in attorney’s fees against a Massachusetts attorney representing a plaintiff in a civil suit filed against...

1st Circuit: “Persistence” On the Part of Injured Employee’s Attorney Results in Attorney Being Sanctioned With Almost $35,000 in Attorney’s Fees 1st Circuit: “Persistence” On the Part of Injured Employee’s Attorney Results in Attorney Being Sanctioned With Almost $35,000 in Attorney’s Fees
Mar 28, 2012

Indiana: After Approval of Settlement Agreement By Board, Estate of Deceased Worker May Not Proceed Against “Employer” in Tort On Basis of Claimed Status as Independent Contractor

Because settlement agreements ordinarily cover only those claims or rights that are specifically mentioned within the four corners of the agreement itself [see Larson’s Workers’ Compensation Law, § 132.05], attention...

Indiana: After Approval of Settlement Agreement By Board, Estate of Deceased Worker May Not Proceed Against “Employer” in Tort On Basis of Claimed Status as Independent Contractor Indiana: After Approval of Settlement Agreement By Board, Estate of Deceased Worker May Not Proceed Against “Employer” in Tort On Basis of Claimed Status as Independent Contractor
Mar 23, 2012

Employer Gets Lesson in Law of Negotiable Instruments–It Remains Liable When Claimant’s Settlement Check is Misdelivered and Forged

An employer, who mailed a $17,000 settlement check to the address erroneously designated by the claimant in a Compromise & Release Agreement (C&R) settling claimant’s workers’ compensation case, is still...

Employer Gets Lesson in Law of Negotiable Instruments–It Remains Liable When Claimant’s Settlement Check is Misdelivered and Forged Employer Gets Lesson in Law of Negotiable Instruments–It Remains Liable When Claimant’s Settlement Check is Misdelivered and Forged

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.