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Feb 19, 2025

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence

In a decision that reinforces the potential consequences of misrepresenting one’s physical condition, a New York appellate court has upheld the permanent disqualification from wage replacement benefits of a workers’...

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence
Feb 18, 2025

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits

In an unpublished decision, a Kansas appellate court has struck down an employer’s attempt to deny workers’ compensation benefits to an employee who refused a drug test 18 days after...

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits
Feb 14, 2025

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim

In Matter of Tudor v. Whitehall Cent. Sch. Dist., 2025 N.Y. App. Div. LEXIS 827 (3d Dept., Feb. 13, 2025), the New York Appellate Division, Third Department, affirmed the state...

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim
Feb 13, 2025

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)

Background On May 21, 1946, Kelly fell and injured his left knee in an accident which arose out of and in the course of his employment with the employer. He...

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949) Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)

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Aug 18, 2012

Pennsylvania: Trip to the Salad Bar Proves Fatal for College Professor

In a case with somewhat bizarre facts [see Pennsylvania State Univ. v. Workers’ Comp. Appeal Bd. (Rabin), 2012 Pa. Commw. LEXIS 245], a Pennsylvania appellate court recently affirmed an award...

Pennsylvania: Trip to the Salad Bar Proves Fatal for College Professor Pennsylvania: Trip to the Salad Bar Proves Fatal for College Professor
Aug 3, 2012

Alabama: Court Reverses Award of Benefits to Truck Driver Bitten by Rattlesnake

As a father of three sons and a daughter–they’re all grown now–I’ve had more than one occasion to repeat to myself a favorite line spoken by another dad, this one...

Alabama: Court Reverses Award of Benefits to Truck Driver Bitten by Rattlesnake Alabama: Court Reverses Award of Benefits to Truck Driver Bitten by Rattlesnake
Aug 2, 2012

VA: Nurse’s Injury to Finger As She Reached Into Personal Handbag To Retrieve “Favorite” Pen Is Not Compensable

The Court of Appeals of Virginia recently reversed a decision by the state’s Workers’ Compensation Commission that had awarded workers’ compensation benefits to a nurse who injured her finger on...

VA: Nurse’s Injury to Finger As She Reached Into Personal Handbag To Retrieve “Favorite” Pen Is Not Compensable VA: Nurse’s Injury to Finger As She Reached Into Personal Handbag To Retrieve “Favorite” Pen Is Not Compensable
Jul 29, 2012

VA: Virginia Court Mischaracterizes “Actual Risk” Test in Determining Legal Causation, Yet Offers Motherly Advice: “Waiters, Take Small Bites!”

Affirming a decision of the state’s Workers’ Compensation Commission that had denied benefits to a restaurant host/waiter who injured his esophagus while attempting to swallow a bite of quesadilla that...

VA: Virginia Court Mischaracterizes “Actual Risk” Test in Determining Legal Causation, Yet Offers Motherly Advice: “Waiters, Take Small Bites!” VA: Virginia Court Mischaracterizes “Actual Risk” Test in Determining Legal Causation, Yet Offers Motherly Advice: “Waiters, Take Small Bites!”
Jul 13, 2012

South Carolina: Deputy Sheriff’s PTSD Claim in Connection With Fatal Shooting of Suspect Is Not Compensable–No “Extraordinary or Unusual Employment Condition” Existed

On Wednesday, a divided Supreme Court of South Carolina affirmed a unanimous finding of an Appellate Panel of the state’s Workers’ Compensation Commission that a deputy sheriff failed to meet...

South Carolina: Deputy Sheriff’s PTSD Claim in Connection With Fatal Shooting of Suspect Is Not Compensable–No “Extraordinary or Unusual Employment Condition” Existed

South Carolina: Deputy Sheriff’s PTSD Claim in Connection With Fatal Shooting of Suspect Is Not Compensable–No “Extraordinary or Unusual Employment Condition” Existed

Jul 12, 2012

Texas: Communication by Comp Carrier’s Counsel to Insured Employer Not Protected by Attorney—Client Privilege

With one justice dissenting, the Supreme Court of Texas recently held that in a bad faith action brought by an injured employee against a workers’ compensation insurer, the attorney—client privilege...

Texas: Communication by Comp Carrier’s Counsel to Insured Employer Not Protected by Attorney—Client Privilege Texas: Communication by Comp Carrier’s Counsel to Insured Employer Not Protected by Attorney—Client Privilege
Jul 4, 2012

New Jersey: OSHA Violation is Insufficient to Show Necessary Level of “Intent” to Support Tort Claim Against Employer

As noted in my June 6, 2012 discussion of Estes v. Airco Serv., Inc., 2012 U.S. Dist. LEXIS 72134 (N.D. Okla., May 24, 2012), below, an important exception to the...

New Jersey: OSHA Violation is Insufficient to Show Necessary Level of “Intent” to Support Tort Claim Against Employer New Jersey: OSHA Violation is Insufficient to Show Necessary Level of “Intent” to Support Tort Claim Against Employer
Jun 30, 2012

Arkansas: Only Partial Offset of Claimant’s Disability Benefits By Retirement Benefits Allowed

Workers’ compensation, unemployment compensation, nonoccupational sickness and disability insurance, and old age and survivors’ and disability insurance are all based upon a common principle and a common operative fact: wage...

Arkansas: Only Partial Offset of Claimant’s Disability Benefits By Retirement Benefits Allowed Arkansas: Only Partial Offset of Claimant’s Disability Benefits By Retirement Benefits Allowed
Jun 29, 2012

Oregon: Police Lieutenant’s Injuries During Coffee Break Are Compensable

On Wednesday, the Court of Appeals of Oregon, in McDermed v. City of Eugene, 2012 Ore. App. LEXIS 796 (June 27, 2012), affirmed an award of workers’ compensation benefits to...

Oregon: Police Lieutenant’s Injuries During Coffee Break Are Compensable Oregon: Police Lieutenant’s Injuries During Coffee Break Are Compensable
Jun 21, 2012

Ohio: Unpaid Work for Wife’s Business Warranted Forfeiture of Benefits, But Not Finding of Fraudulent Activity

The Supreme Court of Ohio, affirming a decision of a lower level appellate court, recently held that while a claimant could not receive temporary total disability (TTD) benefits for any...

Ohio: Unpaid Work for Wife’s Business Warranted Forfeiture of Benefits, But Not Finding of Fraudulent Activity Ohio: Unpaid Work for Wife’s Business Warranted Forfeiture of Benefits, But Not Finding of Fraudulent Activity
Jun 16, 2012

Missouri: Survivors May Proceed in Tort Against Uninsured Employer After Recovering Workers’ Compensation Benefits From Statutory Employer–No Election of Remedies Problem

In a 4–3 decision, the Supreme Court of Missouri recently reversed the decision of a state trial court that earlier had held a workers’ compensation award against a statutory employer...

Missouri: Survivors May Proceed in Tort Against Uninsured Employer After Recovering Workers’ Compensation Benefits From Statutory Employer–No Election of Remedies Problem Missouri: Survivors May Proceed in Tort Against Uninsured Employer After Recovering Workers’ Compensation Benefits From Statutory Employer–No Election of Remedies Problem
Jun 15, 2012

Virginia: Non-Dependent Relative of Deceased Worker Caught in Catch-22

In the vast majority of states, non-dependent relatives of employees who suffer fatal work-related injuries are caught in a Catch-22. Since most state acts limit workers’ compensation death benefits to...

Virginia: Non-Dependent Relative of Deceased Worker Caught in Catch-22 Virginia: Non-Dependent Relative of Deceased Worker Caught in Catch-22

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.