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Jul 16, 2026

Personal Comfort Doctrine Reaches a Formal, Unpaid Break

PA Court Finds a 15-Minute Break’s Brevity Outweighs Its Formality The Commonwealth Court of Pennsylvania recently affirmed an award of workers’ compensation benefits to a pharmacy technician struck by a...

Personal Comfort Doctrine Reaches a Formal, Unpaid Break Personal Comfort Doctrine Reaches a Formal, Unpaid Break
Jul 14, 2026

Trucker’s Retaliation Claim Runs Aground in His Own Hay Field

Idaho Federal Court Finds Surveillance and a Full-Duty Release Defeat Workers' Comp Retaliatory Discharge Claim The U.S. District Court for the District of Idaho recently granted summary judgment for a...

Trucker’s Retaliation Claim Runs Aground in His Own Hay Field Trucker’s Retaliation Claim Runs Aground in His Own Hay Field
Jul 13, 2026

FL High Court Rejects Motive Requirement for Workplace Assault Claims

Risk-Exposure Evidence Alone Can Establish the Causal Link, Justices Hold Last Thursday, In a unanimous decision authored by Justice Muñiz, the Supreme Court of Florida held that a workplace assault...

FL High Court Rejects Motive Requirement for Workplace Assault Claims FL High Court Rejects Motive Requirement for Workplace Assault Claims
Jul 8, 2026

KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths

Supervisors Who Allegedly Blocked Exits Fell Outside the Workers’ Comp Act’s Exclusive Remedy The Kentucky Court of Appeals has revived tort claims brought by survivors of the December 2021 tornado...

KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths

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Apr 28, 2015

Arkansas Court Approves Award of Additional Medical Expenses Related to ER Visit Six Months After Initial Injury

An Arkansas appellate court affirmed a finding by the state’s Workers’ Compensation Commission that an employee was entitled to additional medical benefits when, some six months after an ankle injury,...

Arkansas Court Approves Award of Additional Medical Expenses Related to ER Visit Six Months After Initial Injury Arkansas Court Approves Award of Additional Medical Expenses Related to ER Visit Six Months After Initial Injury
Apr 20, 2015

Who’s “Opting Out” of Workers’ Comp—Employers or the States Themselves?

Recent Federal District Court Discusses ERISA’s Strong Preemption Provisions As I have noted on multiple other occasions, one of the distinctive features of the workers’ compensation “opt out” scheme is...

Who’s “Opting Out” of Workers’ Comp—Employers or the States Themselves? Who’s “Opting Out” of Workers’ Comp—Employers or the States Themselves?
Apr 17, 2015

Virgin Islands: Going and Coming—Is Break Taken to Run Errands a “Lunch” Break

In what Professor Larson would have referred to as an “upside-down” exclusivity case—where the employee tries to prove that her injuries were not covered by the applicable workers’ compensation law...

Virgin Islands: Going and Coming—Is Break Taken to Run Errands a “Lunch” Break Virgin Islands: Going and Coming—Is Break Taken to Run Errands a “Lunch” Break
Apr 14, 2015

West Virginia High Court Crafts Narrow Exception to 6-Month Statute of Limitations in Death Claims

The Supreme Court of Appeals of West Virginia held that where a claimant delays the filing of a workers’ compensation death benefits claim because she was unaware, and could not...

West Virginia High Court Crafts Narrow Exception to 6-Month Statute of Limitations in Death Claims West Virginia High Court Crafts Narrow Exception to 6-Month Statute of Limitations in Death Claims
Apr 13, 2015

SC Court Signals That Uber Business Model Probably OK in the Palmetto State

E-businesses like Uber and Lyft, which utilize smartphone or tablet apps to connect passengers and drivers with vehicles for hire are beginning to carve out a niche within the economy....

SC Court Signals That Uber Business Model Probably OK in the Palmetto State SC Court Signals That Uber Business Model Probably OK in the Palmetto State
Apr 10, 2015

West Virginia Employee’s Unexplained Fall Was Idiopathic And Not Compensable

In a memorandum decision, the Supreme Court of Appeals of West Virginia affirmed the denial of workers’ compensation benefits to an employee who suffered a dislocation of his left knee...

West Virginia Employee’s Unexplained Fall Was Idiopathic And Not Compensable West Virginia Employee’s Unexplained Fall Was Idiopathic And Not Compensable
Apr 9, 2015

PA: Native-American Marriage Ceremony Establishes “Widow’s” Common-law Marriage

On Tuesday, a Pennsylvania appellate court held that a claimant, whose purported husband had been killed in a work-related rollover accident at a ski resort, had presented clear and convincing...

PA: Native-American Marriage Ceremony Establishes “Widow’s” Common-law Marriage PA: Native-American Marriage Ceremony Establishes “Widow’s” Common-law Marriage
Apr 9, 2015

Maryland: Subsequent Injury Fund Assessment Not Reduced Due to Retirement Offset

The 6.5% assessment, payable by a Maryland employer or insurer to the state’s Subsequent Injury Fund on: (i) each award for permanent disability or death, or (ii) each amount payable...

Maryland: Subsequent Injury Fund Assessment Not Reduced Due to Retirement Offset Maryland: Subsequent Injury Fund Assessment Not Reduced Due to Retirement Offset
Apr 8, 2015

Ohio Nurse’s Fall in Hospital ER Was Outside Course and Scope of Employment

A hospital nurse, who fractured her humerus in a fall in her employer’s emergency room when her coat apparently became ensnarled in a wheelchair, did not sustain an injury arising...

Ohio Nurse’s Fall in Hospital ER Was Outside Course and Scope of Employment Ohio Nurse’s Fall in Hospital ER Was Outside Course and Scope of Employment
Apr 7, 2015

Proposed Alaska Legislation Would Clarify That Uber and Lyft Drivers Are Not Entitled to Comp Benefits

As I mentioned in an earlier post, juries in two civil actions pending before a federal court sitting in California will be allowed to determine if Uber and Lyft have...

Proposed Alaska Legislation Would Clarify That Uber and Lyft Drivers Are Not Entitled to Comp Benefits Proposed Alaska Legislation Would Clarify That Uber and Lyft Drivers Are Not Entitled to Comp Benefits
Apr 6, 2015

Kentucky Contractor Immune From Suit Filed by Employee of Subcontractor

Applying Kentucky’s “up-the-ladder immunity” doctrine, a state appellate court vacated a trial court’s refusal to grant summary judgment in favor of a defendant corporation that had been sued in tort...

Kentucky Contractor Immune From Suit Filed by Employee of Subcontractor Kentucky Contractor Immune From Suit Filed by Employee of Subcontractor
Apr 3, 2015

Virginia Employee Who Cures Light Work Refusal Entitled to Comp Benefits

In a decision that has been not been designated for publication, the Court of Appeals of Virginia held that an employee cured his refusal of selective employment (“light work”) where,...

Virginia Employee Who Cures Light Work Refusal Entitled to Comp Benefits Virginia Employee Who Cures Light Work Refusal Entitled to Comp Benefits

New Comments

  • ramivou: They hid behind a flawed "reading" of this statute for a decade. I am glad the SC finally put an end to the misconception that it was a "first six months only" filing requirement, rather than an ongoing responsibility.
  • 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