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Apr 8, 2025

NC Court Rejects Tort Claim for Workplace Fatality

In a decision that underscores the high bar for pursuing civil remedies alongside a workers’ compensation claim, the North Carolina Court of Appeals recently affirmed summary judgment against the estate...

NC Court Rejects Tort Claim for Workplace Fatality NC Court Rejects Tort Claim for Workplace Fatality
Apr 7, 2025

PA Court Upholds Medical-Only Notice of Compensation Payable Issued by Mistake

What happens when a claims adjuster clicks the wrong box in the third-party administrator’s software—and it accidentally binds the employer to a workers’ compensation claim? In City of Philadelphia v....

PA Court Upholds Medical-Only Notice of Compensation Payable Issued by Mistake PA Court Upholds Medical-Only Notice of Compensation Payable Issued by Mistake
Apr 3, 2025

Throwback Thursday: Graybeal v. Board of Supervisors (1975)

Rethinking the Limits of “Course of Employment” In traditional workers’ compensation doctrine, an injury must not only “arise out of” employment but also occur “in the course of” employment. Courts...

Throwback Thursday: Graybeal v. Board of Supervisors (1975) Throwback Thursday: Graybeal v. Board of Supervisors (1975)
Apr 1, 2025

Rear-Ended While Intoxicated—and Still Covered: A Careful Reading of NY’s § 10(1)

In a bizarre case that turned on the precise wording of N.Y. Workers' Comp. Law § 10(1), a state appellate court affirmed a Board decision awarding benefits to a claimant...

Rear-Ended While Intoxicated—and Still Covered: A Careful Reading of NY’s § 10(1) Rear-Ended While Intoxicated—and Still Covered: A Careful Reading of NY’s § 10(1)

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Apr 5, 2012

Ohio: Trauma Induced Stroke Sustained In Fall From Wheelchair Is Not Compensable Aggravation of Original Injury

A worker, who lost the use of his legs in 1965 in a work-related accident, and who was thereafter confined to a wheelchair, is not entitled to additional workers compensation...

Ohio: Trauma Induced Stroke Sustained In Fall From Wheelchair Is Not Compensable Aggravation of Original Injury Ohio: Trauma Induced Stroke Sustained In Fall From Wheelchair Is Not Compensable Aggravation of Original Injury
Apr 1, 2012

1st Circuit: “Persistence” On the Part of Injured Employee’s Attorney Results in Attorney Being Sanctioned With Almost $35,000 in Attorney’s Fees

The First Circuit Court of Appeals recently affirmed sanctions in the form of $34,908.12 in attorney’s fees against a Massachusetts attorney representing a plaintiff in a civil suit filed against...

1st Circuit: “Persistence” On the Part of Injured Employee’s Attorney Results in Attorney Being Sanctioned With Almost $35,000 in Attorney’s Fees 1st Circuit: “Persistence” On the Part of Injured Employee’s Attorney Results in Attorney Being Sanctioned With Almost $35,000 in Attorney’s Fees
Mar 28, 2012

Indiana: After Approval of Settlement Agreement By Board, Estate of Deceased Worker May Not Proceed Against “Employer” in Tort On Basis of Claimed Status as Independent Contractor

Because settlement agreements ordinarily cover only those claims or rights that are specifically mentioned within the four corners of the agreement itself [see Larson’s Workers’ Compensation Law, § 132.05], attention...

Indiana: After Approval of Settlement Agreement By Board, Estate of Deceased Worker May Not Proceed Against “Employer” in Tort On Basis of Claimed Status as Independent Contractor Indiana: After Approval of Settlement Agreement By Board, Estate of Deceased Worker May Not Proceed Against “Employer” in Tort On Basis of Claimed Status as Independent Contractor
Mar 23, 2012

Employer Gets Lesson in Law of Negotiable Instruments–It Remains Liable When Claimant’s Settlement Check is Misdelivered and Forged

An employer, who mailed a $17,000 settlement check to the address erroneously designated by the claimant in a Compromise & Release Agreement (C&R) settling claimant’s workers’ compensation case, is still...

Employer Gets Lesson in Law of Negotiable Instruments–It Remains Liable When Claimant’s Settlement Check is Misdelivered and Forged Employer Gets Lesson in Law of Negotiable Instruments–It Remains Liable When Claimant’s Settlement Check is Misdelivered and Forged
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

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...