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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

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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
Dec 31, 2012

Arkansas: Diabetic Ulcer Claim Related to Toe Blister From Employee-Supplied Boots Found Compensable

The Supreme Court of Arkansas, construing the state’s restrictive statute regarding the compensability of repetitive motion injuries, recently reversed a decision by the state’s Workers’ Compensation Commission that had denied,...

Arkansas: Diabetic Ulcer Claim Related to Toe Blister From Employee-Supplied Boots Found Compensable Arkansas: Diabetic Ulcer Claim Related to Toe Blister From Employee-Supplied Boots Found Compensable
Dec 20, 2012

Florida: Truck Driver Is Employed During Two-Day “Orientation” and is Entitled To Workers’ Compensation Benefits

A truck driver, who sustained injuries in an automobile accident as he traveled to lunch on the second day of a two-day orientation program was an employee of the trucking...

Florida: Truck Driver Is Employed During Two-Day “Orientation” and is Entitled To Workers’ Compensation Benefits Florida: Truck Driver Is Employed During Two-Day “Orientation” and is Entitled To Workers’ Compensation Benefits
Dec 19, 2012

Kentucky: Teacher’s Tort Action Against Snake-Handling Assistant Principal Barred by Exclusivity

The Court of Appeals of Kentucky recently affirmed a state trial court’s summary judgment in favor of a high school assistant principal and a county board of education in a...

Kentucky: Teacher’s Tort Action Against Snake-Handling Assistant Principal Barred by Exclusivity Kentucky: Teacher’s Tort Action Against Snake-Handling Assistant Principal Barred by Exclusivity
Dec 16, 2012

US: Office Worker’s Tort Action Against Dentist Employer Alleging Sexual Assault Not Barred by Exclusivity

In Painter v. Atwood, 2012 U.S. Dist. LEXIS 176655 (D. Nev., Dec. 12, 2012), a federal district court from Nevada recently held, in relevant part, that a civil action filed...

US: Office Worker’s Tort Action Against Dentist Employer Alleging Sexual Assault Not Barred by Exclusivity US: Office Worker’s Tort Action Against Dentist Employer Alleging Sexual Assault Not Barred by Exclusivity
Dec 5, 2012

Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative

Reversing the state’s Court of Appeals, the Supreme Court of Georgia has ruled that an employee who filed a claim under the state’s Workers’ Compensation Act, must authorize her treating...

Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative
Nov 23, 2012

Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded

An Arizona appellate court recently held, as a matter of law, that a workers’ compensation claimant who expressed an intention to record an independent medical examination (“IME”), in the absence...

Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded
Nov 21, 2012

LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell

Under the Longshore and Harbor Workers’ Compensation Act (“LHWCA”), no compensation is payable “if the injury was occasioned solely by the intoxication of the employee” [see 33 U.S.C. § 903(c)]....

LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell
Nov 19, 2012

Getting Hurt “On the Job”

As I’ve mentioned in my last several posts, a bit more than a week ago, I enjoyed being part of three panel discussions at the 21st Annual National Workers’ Compensation...

Getting Hurt “On the Job” Getting Hurt “On the Job”

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...