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Jun 3, 2025

Iowa High Court Says Gross Negligence/Fraud Claims Can Go Forward Against Tyson Executives

In an important decision construing the Iowa doctrine that allows gross negligence and fraudulent misrepresentation tort claims against co-employees, the Iowa Supreme Court has revived claims against Tyson Foods executives...

Iowa High Court Says Gross Negligence/Fraud Claims Can Go Forward Against Tyson Executives Iowa High Court Says Gross Negligence/Fraud Claims Can Go Forward Against Tyson Executives
May 29, 2025

Throwback Thursday: Prows v. Industrial Commission of Utah (1980)

A Horseplay Case That Shaped Utah’s Workers’ Compensation Doctrine In Prows v. Industrial Commission of Utah, 610 P.2d 1362 (Utah 1980), the Supreme Court of Utah was presented with a...

Throwback Thursday: Prows v. Industrial Commission of Utah (1980) Throwback Thursday: Prows v. Industrial Commission of Utah (1980)
May 27, 2025

When the Boss Wears Two Hats

Exclusivity Does Not Shield Corporate Officers/Property Owners From Liability as Landlords In Nelson v. Smith, 2025 N.C. App. LEXIS 306 (May 21, 2025), the North Carolina Court of Appeals reversed...

When the Boss Wears Two Hats When the Boss Wears Two Hats
May 22, 2025

Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975)

Tools, Timing, and Termination In Nails v. Market Tire Co., 29 Md. App. 154, 347 A.2d 564 (Md. Ct. Spec. App. 1975), the Maryland Court of Special Appeals addressed a...

Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975) Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975)

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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”
Jan 4, 2013

Divided Supreme Court of Montana Says Statute Defining Religious Order as Employer (For Workers’ Compensation Purposes) is Not Unconstitutional

On the last day of 2012, and in a split decision, the Supreme Court of Montana reversed a trial court’s summary judgment decision that had earlier determined that the requirement...

Divided Supreme Court of Montana Says Statute Defining Religious Order as Employer (For Workers’ Compensation Purposes) is Not Unconstitutional Divided Supreme Court of Montana Says Statute Defining Religious Order as Employer (For Workers’ Compensation Purposes) is Not Unconstitutional
Jan 4, 2013

D.C. Circuit Court: Personal Representative’s Civil Action Against Employer for Negligent Provision of Firearm to Suicide Victim/Employee May Not Proceed

In a case with a number of interesting twists, the Court of Appeals for the D.C. Circuit recently affirmed a decision by a U.S. District Court that, in relevant part,...

D.C. Circuit Court: Personal Representative’s Civil Action Against Employer for Negligent Provision of Firearm to Suicide Victim/Employee May Not Proceed D.C. Circuit Court: Personal Representative’s Civil Action Against Employer for Negligent Provision of Firearm to Suicide Victim/Employee May Not Proceed
Dec 31, 2012

Missouri: Retaliatory Discharge Statute Requires Former Employee to Establish that Exercise of Rights Was Exclusive, Not Merely a Contributing, Factor in Firing

A Missouri appellate court recently affirmed a jury verdict in favor of a former employer on a former employee’s claim of retaliatory discharge and agreed that the former employee was...

Missouri: Retaliatory Discharge Statute Requires Former Employee to Establish that Exercise of Rights Was Exclusive, Not Merely a Contributing, Factor in Firing Missouri: Retaliatory Discharge Statute Requires Former Employee to Establish that Exercise of Rights Was Exclusive, Not Merely a Contributing, Factor in Firing
Dec 31, 2012

Michigan Becomes 5th State to Pass Social Media Law Affecting Employers’ Right to Private Information

On December 28, Michigan became the 5th state to pass a social media privacy law. House Bill 5523, entitled the Internet Privacy Protection Act, was signed by Gov. Rick Snyder...

Michigan Becomes 5th State to Pass Social Media Law Affecting Employers’ Right to Private Information Michigan Becomes 5th State to Pass Social Media Law Affecting Employers’ Right to Private Information

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...