Newest Articles

May 12, 2025

Final Means Final—Even When the Law Changes

Favorable Ruling by NY High Court Cannot Support Employer’s Reopening Request In Matter of Coyle v. W & W Steel Erectors LLC, 2025 N.Y. App. Div. LEXIS 2889 (3d Dept....

Final Means Final—Even When the Law Changes Final Means Final—Even When the Law Changes
May 8, 2025

Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948)

Imported Quarrels and the Boundaries of Employment Risk In Bridges v. Elite, Inc., 212 S.C. 514, 48 S.E.2d 497 (S.C. 1948), the Supreme Court of South Carolina reversed a decision...

Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948) Throwback Thursday: Bridges v. Elite, Inc. (S.C. 1948)
May 7, 2025

NY Court Clarifies When Financial Hardship Justifies Total Disability

Construing an exception to New York’s cap on permanent partial disability (PPD) benefits [see N.Y. Workers’ Comp. Law, § 35(3)], which allows—in certain situations—reclassification of the claimant’s disability to permanent...

NY Court Clarifies When Financial Hardship Justifies Total Disability NY Court Clarifies When Financial Hardship Justifies Total Disability
May 6, 2025

California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute

In a decision reemphasizing the boundaries of compensability for commuting injuries, the California Court of Appeal (Third Appellate District) has annulled a WCAB award awarding workers’ compensation benefits to a...

California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute California Court Reverses WCAB’s Award for Carpool Injuries Sustained During Commute

All Articles

ARCHIVE
2025
2024
2023
2022
2021
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
Mar 27, 2013

Maine: Employer Not Entitled to Offset Incapacity Benefits Against Specific Loss Award for Amputation

The Supreme Judicial Court of Maine recently reversed an award by the state’s Workers’ Compensation Board that had granted an employee specific loss benefits for the amputation of a finger,...

Maine: Employer Not Entitled to Offset Incapacity Benefits Against Specific Loss Award for Amputation Maine: Employer Not Entitled to Offset Incapacity Benefits Against Specific Loss Award for Amputation
Mar 25, 2013

New York: No Death Benefits Awarded Where Work-Related Heart Attack Occurred 24 Years Earlier

A New York appellate court recently affirmed a finding by the state’s Workers’ Compensation Board that ruled that the death of claimant’s husband was not causally related to his employment...

New York: No Death Benefits Awarded Where Work-Related Heart Attack Occurred 24 Years Earlier New York: No Death Benefits Awarded Where Work-Related Heart Attack Occurred 24 Years Earlier
Mar 23, 2013

Ohio: Appellate Court Distinguishes Case from Earlier Moorehead Decision: No Loss of Use of Trucker’s Legs Where He May Have Survived Wreck for Brief Period of Time

An Ohio appellate court recently affirmed a decision by the state’s Industrial Commission that had denied additional workers’ compensation benefits for the scheduled loss of use of both of a...

Ohio: Appellate Court Distinguishes Case from Earlier Moorehead Decision: No Loss of Use of Trucker’s Legs Where He May Have Survived Wreck for Brief Period of Time Ohio: Appellate Court Distinguishes Case from Earlier Moorehead Decision: No Loss of Use of Trucker’s Legs Where He May Have Survived Wreck for Brief Period of Time
Mar 19, 2013

Ohio: Truck Driver’s Termination For Causing Accident in Which He Sustained Injuries Does Not Disqualify Him From TTD Benefits

In State ex rel. Haddox v. Industrial Comm’n, 2013 Ohio 794, 2013 Ohio LEXIS 618 (Mar. 12, 2013), the Supreme Court of Ohio recently affirmed an appellate court’s decision that...

Ohio: Truck Driver’s Termination For Causing Accident in Which He Sustained Injuries Does Not Disqualify Him From TTD Benefits Ohio: Truck Driver’s Termination For Causing Accident in Which He Sustained Injuries Does Not Disqualify Him From TTD Benefits
Feb 24, 2013

Washington: School Custodian’s Tort Claim Against Employer for PTSD Resulting From Clean-up Duties Following Student’s Suicide Is Barred by Exclusivity

Last Thursday, a Washington state appellate court affirmed the dismissal of a civil action filed by a school custodian against her employer, a school district and its superintendent, alleging intentional...

Washington: School Custodian’s Tort Claim Against Employer for PTSD Resulting From Clean-up Duties Following Student’s Suicide Is Barred by Exclusivity Washington: School Custodian’s Tort Claim Against Employer for PTSD Resulting From Clean-up Duties Following Student’s Suicide Is Barred by Exclusivity
Feb 23, 2013

New York: Mechanic’s Fatal Heart Attack Sustained on Employer’s Premises, But After Work Shift, Held Not Compensable

A New York appellate court recently affirmed a decision by the state’s Workers’ Compensation Board that ruled the death of an employee was not causally related to his employment as...

New York: Mechanic’s Fatal Heart Attack Sustained on Employer’s Premises, But After Work Shift, Held Not Compensable New York: Mechanic’s Fatal Heart Attack Sustained on Employer’s Premises, But After Work Shift, Held Not Compensable
Feb 16, 2013

South Carolina: Supreme Court Adopts Larson’s “Dual Persona” Doctrine

Answering a question certified to it by the U.S. District Court for the District of South Carolina, the Supreme Court of South Carolina, in Mendenall v. Anderson Hardwood Floors, Inc.,...

South Carolina: Supreme Court Adopts Larson’s “Dual Persona” Doctrine South Carolina: Supreme Court Adopts Larson’s “Dual Persona” Doctrine
Feb 8, 2013

North Carolina: Intentional Tort Action Against Wal-Mart Related to Death of Wal-Mart “Greeter” Barred by Exclusivity

On Tuesday, the Court of Appeals of North Carolina affirmed a trial court’s order granting various defendants’ motions for summary judgment on exclusivity grounds in a wrongful death action filed...

North Carolina: Intentional Tort Action Against Wal-Mart Related to Death of Wal-Mart “Greeter” Barred by Exclusivity North Carolina: Intentional Tort Action Against Wal-Mart Related to Death of Wal-Mart “Greeter” Barred by Exclusivity
Feb 5, 2013

Kentucky: Convenience Store Worker’s Access to Premises and Security Codes Provides Causal Link Between His Murder and the Employment

The Court of Appeals of Kentucky recently affirmed an award of death benefits to the administratrix of the estate of a deceased convenience store worker (“Pendleton”) who was found after...

Kentucky: Convenience Store Worker’s Access to Premises and Security Codes Provides Causal Link Between His Murder and the Employment Kentucky: Convenience Store Worker’s Access to Premises and Security Codes Provides Causal Link Between His Murder and the Employment
Jan 24, 2013

Florida: Court Reverses Injured Worker’s $2.7 Million Verdict Against Employer: Injury Was Not “Virtually Certain”

In a workers’ compensation immunity case, the Court of Appeal of Florida (Fourth District) yesterday reversed a $2.7 million jury verdict and final judgment in favor of an employee who...

Florida: Court Reverses Injured Worker’s $2.7 Million Verdict Against Employer: Injury Was Not “Virtually Certain” Florida: Court Reverses Injured Worker’s $2.7 Million Verdict Against Employer: Injury Was Not “Virtually Certain”
Jan 21, 2013

Louisiana: Police Sergeant’s Short Trip to Headquarters To Get Cash From Credit Union Was Deviation From Employment; Injuries in Stairwell Not Compensable

A Louisiana appellate court recently affirmed the denial of a claim filed by a police sergeant who sustained injuries when he fell in a stairwell at Police Headquarters following a...

Louisiana: Police Sergeant’s Short Trip to Headquarters To Get Cash From Credit Union Was Deviation From Employment; Injuries in Stairwell Not Compensable Louisiana: Police Sergeant’s Short Trip to Headquarters To Get Cash From Credit Union Was Deviation From Employment; Injuries in Stairwell Not Compensable
Jan 7, 2013

Ohio: Appellate Court Affirms Award for PTSD in Spite of State’s Limiting Definition of “Injury”

An Ohio appellate court recently affirmed a trial court’s summary judgment in favor of a medical center clerk who had received an award of workers’ compensation benefits related to physical...

Ohio: Appellate Court Affirms Award for PTSD in Spite of State’s Limiting Definition of “Injury” Ohio: Appellate Court Affirms Award for PTSD in Spite of State’s Limiting Definition of “Injury”

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...