Newest Articles

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

All Articles

ARCHIVE
2024
2023
2022
2021
2020
2019
2018
2017
2016
2015
2014
2013
2012
2011
Mar 16, 2012

Tennessee: Employee Denied Benefits for Unexplained Fall to Level Floor

In a recent case from Tennessee, Byrom v. Randstad N. Am., L.P., 2012 Tenn. LEXIS 152 (Mar. 8, 2012), a special appeals panel of the state supreme court affirmed a...

Tennessee: Employee Denied Benefits for Unexplained Fall to Level Floor Tennessee: Employee Denied Benefits for Unexplained Fall to Level Floor
Mar 8, 2012

Wyoming: High Court Finds Injured HVAC Worker Established “Odd Lot” Status”

Under the “odd-lot” doctrine, accepted in the vast majority of jurisdictions, total disability may be found in the case of workers who, while not altogether incapacitated for work, are so...

Wyoming: High Court Finds Injured HVAC Worker Established “Odd Lot” Status” Wyoming: High Court Finds Injured HVAC Worker Established “Odd Lot” Status”
Feb 29, 2012

New Hampshire Court Limits Firefighter’s Rule–Slip and Fall Action by Firefighter May Continue Against Homeowner

“Danger invites rescue,” wrote Judge Benjamin Cordozo in his typical profound and pithy manner [see Wagner v. International Railway, 232 N.Y. 176, 133 N.E. 437 (1921)]. Cordozo’s pronouncement is generally...

New Hampshire Court Limits Firefighter’s Rule–Slip and Fall Action by Firefighter May Continue Against Homeowner New Hampshire Court Limits Firefighter’s Rule–Slip and Fall Action by Firefighter May Continue Against Homeowner
Feb 25, 2012

Tennessee: Combination of Injury and Cocktail of Medications to Treat Nurse’s Continuing Symptoms Equates to Permanent and Total Disability Award

A Special Workers’ Compensation Panel of the Supreme Court of Tennessee recently affirmed a judgment of a trial court that found a worker, a registered nurse, to be permanently and...

Tennessee: Combination of Injury and Cocktail of Medications to Treat Nurse’s Continuing Symptoms Equates to Permanent and Total Disability Award Tennessee: Combination of Injury and Cocktail of Medications to Treat Nurse’s Continuing Symptoms Equates to Permanent and Total Disability Award
Feb 20, 2012

Federal District Court Grants Motion in Limine to Exclude Evidence of Workers’ Comp Benefits Received By Plaintiff

It has long been held that an injured employee should not be allowed to keep the entire amount of his or her workers’ compensation award and also the full common-law...

Federal District Court Grants Motion in Limine to Exclude Evidence of Workers’ Comp Benefits Received By Plaintiff Federal District Court Grants Motion in Limine to Exclude Evidence of Workers’ Comp Benefits Received By Plaintiff
Feb 17, 2012

Six-Day Delay in Getting Offshore Worker Medical Treatment For Stroke Supports Aggravation Claim Under Longshore Act

One of the important axioms of workers’ compensation law is that, generally, the employer takes the employee as it finds that employee [see Larson’s Workers’ Compensation Law, § 9.02]. That...

Six-Day Delay in Getting Offshore Worker Medical Treatment For Stroke Supports Aggravation Claim Under Longshore Act Six-Day Delay in Getting Offshore Worker Medical Treatment For Stroke Supports Aggravation Claim Under Longshore Act
Feb 10, 2012

Worker Claims He Was Fired For Refusing to Wear Safety Program’s “Mark of the Beast”

What’s In a Number? Two years ago, when I got my current cell phone, the cell phone company randomly assigned my new number. I looked at the sticker on the...

Worker Claims He Was Fired For Refusing to Wear Safety Program’s “Mark of the Beast” Worker Claims He Was Fired For Refusing to Wear Safety Program’s “Mark of the Beast”
Feb 10, 2012

Facebook Party Pics Help Defeat Worker’s Claim for Benefits

Until a number of my high school classmates began to plan our 40th reunion gala several years ago, I had successfully avoided Facebook® and the other social media (I’m still...

Facebook Party Pics Help Defeat Worker’s Claim for Benefits Facebook Party Pics Help Defeat Worker’s Claim for Benefits
Feb 4, 2012

In Spite of Statutory Presumptions, Proof of Positive Drug Test May Not Be Enough to Defeat Claims

In the great majority of jurisdictions, voluntary intoxication that renders an employee incapable of performing his or her work is a departure from the course of employment sufficient to defeat...

In Spite of Statutory Presumptions, Proof of Positive Drug Test May Not Be Enough to Defeat Claims In Spite of Statutory Presumptions, Proof of Positive Drug Test May Not Be Enough to Defeat Claims
Feb 2, 2012

Ohio: Cautious Medical Testimony Dooms Death Benefits Claim Related to “Poster Child for Heart Disease”

An Ohio appellate court recently found that medical evidence presented in a death claim case was too speculative to support the required causal connection between a worker’s fatal heart attack...

Ohio: Cautious Medical Testimony Dooms Death Benefits Claim Related to “Poster Child for Heart Disease” Ohio: Cautious Medical Testimony Dooms Death Benefits Claim Related to “Poster Child for Heart Disease”
Jan 27, 2012

“By Accident,” the Oft-Ignored Provision in Workers’ Compensation Law

Virtually every jurisdiction’s comp act has a “by accident” provision of some sort in its definition of compensable injury [for an extended discussion, see Larson’s Workers’ Compensation Law, § 42.01,...

“By Accident,” the Oft-Ignored Provision in Workers’ Compensation Law “By Accident,” the Oft-Ignored Provision in Workers’ Compensation Law
Jan 27, 2012

Nurse Assistant’s Allegations That She Was Fired For Getting Pregnant Cannot Support Emotional Distress Claim Against Former Employer

A Pennsylvania nurse assistant, who claimed she suffered emotional distress when she was fired for getting pregnant, may not pursue her tort claim against the former employer in federal court,...

Nurse Assistant’s Allegations That She Was Fired For Getting Pregnant Cannot Support Emotional Distress Claim Against Former Employer Nurse Assistant’s Allegations That She Was Fired For Getting Pregnant Cannot Support Emotional Distress Claim Against Former Employer

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.