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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In an unpublished decision, a Kansas appellate court has struck down an employer’s attempt to deny workers’ compensation benefits to an employee who refused a drug test 18 days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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Jun 8, 2012

Maryland: Supervisor May Be Sued By Co-Employee re: Parking Lot Vehicular Accident

All but four states (Arkansas, Missouri, Maryland, Vermont, plus the Virgin Islands) extend immunity from tort liability not only to the employer, but co-employees, at least as long as the...

Maryland: Supervisor May Be Sued By Co-Employee re: Parking Lot Vehicular Accident Maryland: Supervisor May Be Sued By Co-Employee re: Parking Lot Vehicular Accident
Jun 6, 2012

US: 2010 Statutory Amendment Spelled “Certain” Demise of Oklahoma’s “Substantially Certain” Rule in Intentional Injury Actions Against Employers

An important exception to the exclusive remedy rule relates to intentional injury inflicted by the employer on an employee. Several legal theories have been advanced to support the exception. The...

US: 2010 Statutory Amendment Spelled “Certain” Demise of Oklahoma’s “Substantially Certain” Rule in Intentional Injury Actions Against Employers US: 2010 Statutory Amendment Spelled “Certain” Demise of Oklahoma’s “Substantially Certain” Rule in Intentional Injury Actions Against Employers
May 31, 2012

Missouri: Divided Supreme Court Reverses Award of Benefits to Employee Injured Making Coffee for Herself and Others in the Office Kitchen

The Supreme Court of Missouri, in a split decision, construing the state’s version of the “increased-risk” doctrine, on Tuesday (May 29) reversed an award of workers’ compensation benefits to an...

Missouri: Divided Supreme Court Reverses Award of Benefits to Employee Injured Making Coffee for Herself and Others in the Office Kitchen Missouri: Divided Supreme Court Reverses Award of Benefits to Employee Injured Making Coffee for Herself and Others in the Office Kitchen
May 29, 2012

Virginia: Claimant Awarded Post-Termination PD Benefits; Her Poor Performance Was In Part Tied to Her Compensable Injuries

As noted by Larson’s Workers’ Compensation Law, § 84.02 et seq., some of the most complex disability questions arise when the claimant returns to some kind of employment after the...

Virginia: Claimant Awarded Post-Termination PD Benefits; Her Poor Performance Was In Part Tied to Her Compensable Injuries Virginia: Claimant Awarded Post-Termination PD Benefits; Her Poor Performance Was In Part Tied to Her Compensable Injuries
May 25, 2012

Kentucky: Stable Groom, Injured In Auto Accident Returning to Kentucky From New York, Was “Traveling Employee” In Spite of Indefinite Nature of Travel Details

A stable groom for a horse farm, who sustained multiple injuries in an automobile accident that occurred while he rode with a friend back to Kentucky from Saratoga, New York,...

Kentucky: Stable Groom, Injured In Auto Accident Returning to Kentucky From New York, Was “Traveling Employee” In Spite of Indefinite Nature of Travel Details Kentucky: Stable Groom, Injured In Auto Accident Returning to Kentucky From New York, Was “Traveling Employee” In Spite of Indefinite Nature of Travel Details
May 24, 2012

Illinois: Safety Inspectors Are Immune From Tort Liability For Negligent Inspection

An integral and important part of the workers’ compensation “bargain” is the notion that once a workers’ compensation act has become applicable, either through compulsion or election, it affords the...

Illinois: Safety Inspectors Are Immune From Tort Liability For Negligent Inspection Illinois: Safety Inspectors Are Immune From Tort Liability For Negligent Inspection
May 11, 2012

Texas Widow Prevails In Death Claim Case By Showing Husband’s Drug Overdose Could Have Been Caused By Side Effects of Prescription Pain Medication

It is axiomatic in workers’ compensation law that a subsequent injury, whether an aggravation of the original injury or a new and distinct injury, is compensable if it is the...

Texas Widow Prevails In Death Claim Case By Showing Husband’s Drug Overdose Could Have Been Caused By Side Effects of Prescription Pain Medication Texas Widow Prevails In Death Claim Case By Showing Husband’s Drug Overdose Could Have Been Caused By Side Effects of Prescription Pain Medication
May 8, 2012

Oklahoma Opt Out Legislation Fails: A Post Mortem

By Thomas A. Robinson Late last Wednesday evening (April 25th), supporters of a controversial bill that would have allowed some Oklahoma employers to “opt out” of the state’s traditional workers’...

Oklahoma Opt Out Legislation Fails: A Post Mortem Oklahoma Opt Out Legislation Fails: A Post Mortem
Apr 27, 2012

Oklahoma’s Controversial “Opt Out” Legislation Fails (At Least Temporarily)

Late Wednesday evening, supporters of a controversial bill that would allow some Oklahoma employers to “opt out” of the state’s traditional workers’ compensation system [see Oklahoma House Bill 2155] fell...

Oklahoma’s Controversial “Opt Out” Legislation Fails (At Least Temporarily) Oklahoma’s Controversial “Opt Out” Legislation Fails (At Least Temporarily)
Apr 21, 2012

The Fight Against Workers’ Compensation Fraud Takes Many Forms–Florida Goes After Unscrupulous Check Cashing Firms

In August 2007, the Supreme Court of Florida ordered the empanelment of a statewide grand jury to investigate various criminal offenses, including activities related to check cashers. In 2008, the...

The Fight Against Workers’ Compensation Fraud Takes Many Forms–Florida Goes After Unscrupulous Check Cashing Firms The Fight Against Workers’ Compensation Fraud Takes Many Forms–Florida Goes After Unscrupulous Check Cashing Firms
Apr 18, 2012

Virginia Court Affirms Denial of Benefits Related to Unexplained Fall In Spite of Evidence That Claimant’s Step From Truck Was Larger Than Normal Staircase Distance

In yesterday’s post, I pointed out the difficulty courts (and not a few practitioners) have had with a specific form of neutral risk–those in which an employee falls while walking...

Virginia Court Affirms Denial of Benefits Related to Unexplained Fall In Spite of Evidence That Claimant’s Step From Truck Was Larger Than Normal Staircase Distance Virginia Court Affirms Denial of Benefits Related to Unexplained Fall In Spite of Evidence That Claimant’s Step From Truck Was Larger Than Normal Staircase Distance
Apr 17, 2012

North Dakota Supreme Court Refuses to Adopt Positional Risk Doctrine in Unexplained Fall Cases

There’s nothing like an employee’s unexplained fall while walking on a level, unobstructed floor to test one’s position on the positional risk doctrine in workers’ compensation claims. As was noted...

North Dakota Supreme Court Refuses to Adopt Positional Risk Doctrine in Unexplained Fall Cases North Dakota Supreme Court Refuses to Adopt Positional Risk Doctrine in Unexplained Fall Cases

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.