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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)
Mar 31, 2025

Independent Contractor Peace Officer Not Covered by Workers’ Compensation

Texas Court Applies Motor Carrier Exception to General Contractor Rule A Texas appellate court has affirmed a trial court’s take-nothing judgment in favor of Texas Mutual Insurance Company, concluding that...

Independent Contractor Peace Officer Not Covered by Workers’ Compensation Independent Contractor Peace Officer Not Covered by Workers’ Compensation
Mar 27, 2025

Throwback Thursday: New York Central R. Co. v. White (1917)

Background The early 20th century saw a seismic shift in how American society approached workplace injuries. Before the widespread adoption of workers' compensation laws, injured workers typically had to sue...

Throwback Thursday: New York Central R. Co. v. White (1917) Throwback Thursday: New York Central R. Co. v. White (1917)
Mar 26, 2025

Routine Disciplinary Meeting Not a Compensable “Accident” Under NC’ Comp Act

In Muse v. Daimler Trucks N. Am., 2025 N.C. App. LEXIS 113 (Mar. 19, 2025), the North Carolina Court of Appeals affirmed the Industrial Commission’s denial of workers’ compensation benefits...

Routine Disciplinary Meeting Not a Compensable “Accident” Under NC’ Comp Act Routine Disciplinary Meeting Not a Compensable “Accident” Under NC’ Comp Act

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Jan 27, 2012

Nurse Assistant’s Allegations That She Was Fired For Getting Pregnant Cannot Support Emotional Distress Claim Against Former Employer

A Pennsylvania nurse assistant, who claimed she suffered emotional distress when she was fired for getting pregnant, may not pursue her tort claim against the former employer in federal court,...

Nurse Assistant’s Allegations That She Was Fired For Getting Pregnant Cannot Support Emotional Distress Claim Against Former Employer Nurse Assistant’s Allegations That She Was Fired For Getting Pregnant Cannot Support Emotional Distress Claim Against Former Employer
Jan 22, 2012

New York: Apportionment Not Available Between Work-Related Asbestosis and Non-Work-Related Thyroid Cancer in Death Benefits Case

Last Thursday, a New York appellate court recently affirmed a decision by the state’s Workers’ Compensation Board that had determined that a worker’s death was causally related to his employment...

New York: Apportionment Not Available Between Work-Related Asbestosis and Non-Work-Related Thyroid Cancer in Death Benefits Case New York: Apportionment Not Available Between Work-Related Asbestosis and Non-Work-Related Thyroid Cancer in Death Benefits Case
Jan 20, 2012

Virginia Court: Removal of Ankle Prosthesis, Without its Replacement, Does Not Trigger Reopening Statute

Recognizing that no matter how competent and reasonable a commission or board’s determination of a claimant’s medical condition and level of disability might be at the time of a hearing,...

Virginia Court: Removal of Ankle Prosthesis, Without its Replacement, Does Not Trigger Reopening Statute Virginia Court: Removal of Ankle Prosthesis, Without its Replacement, Does Not Trigger Reopening Statute
Jan 14, 2012

Georgia Appellate Court: Effort to Stop Runaway Car is Not a Deviation From the Employment

Last Wednesday, a Georgia appellate court, holding the State Board of Workers’ Compensation had utilized an “erroneous theory” regarding what conduct constitutes a deviation from employment that will bar compensation...

Georgia Appellate Court: Effort to Stop Runaway Car is Not a Deviation From the Employment Georgia Appellate Court: Effort to Stop Runaway Car is Not a Deviation From the Employment
Jan 12, 2012

Arkansas Court Affirms Denial of Benefits; Explosion Caused By Worker’s Marijuana Use

In a split decision, the Arkansas Court of Appeals yesterday affirmed a finding by the state’s Workers’ Compensation Commission that an injured worker failed to rebut the statutory presumption that...

Arkansas Court Affirms Denial of Benefits; Explosion Caused By Worker’s Marijuana Use Arkansas Court Affirms Denial of Benefits; Explosion Caused By Worker’s Marijuana Use
Jan 11, 2012

New York Correctional Facility Superintendent’s Achilles Tendon Injury While Coaching Volleyball Team is Compensable In Spite of Statute Limiting Definition of “Injury”

A New York appellate court, in Nichols v. Hale Creek ASACTC, 2012 N.Y. App. LEXIS 79 (Jan. 5, 2012) has affirmed an award of workers’ compensation benefits to a superintendent...

New York Correctional Facility Superintendent’s Achilles Tendon Injury While Coaching Volleyball Team is Compensable In Spite of Statute Limiting Definition of “Injury” New York Correctional Facility Superintendent’s Achilles Tendon Injury While Coaching Volleyball Team is Compensable In Spite of Statute Limiting Definition of “Injury”
Jan 6, 2012

New York Case Illustrates That Correlation Between Years of Heavy Work and Back Problems Is Insufficient to Support Compensability

A New York decision reported yesterday, Satalino v. Dan’s Supreme Supermarket, 2012 NY Slip Op 86, 2012 N.Y. App. Div. LEXIS 63 (Jan. 5, 2012), illustrates the important distinction between...

New York Case Illustrates That Correlation Between Years of Heavy Work and Back Problems Is Insufficient to Support Compensability New York Case Illustrates That Correlation Between Years of Heavy Work and Back Problems Is Insufficient to Support Compensability
Dec 29, 2011

Ohio Court Nixes Post Traumatic Stress Disorder Claim in Spite of Close Ties With Truck Driver’s Compensable Physical Injuries

A divided Ohio appellate court recently affirmed a trial court’s final judgment that denied a dump truck driver’s claim for post traumatic stress disorder (“PTSD”) in spite of strong medical...

Ohio Court Nixes Post Traumatic Stress Disorder Claim in Spite of Close Ties With Truck Driver’s Compensable Physical Injuries Ohio Court Nixes Post Traumatic Stress Disorder Claim in Spite of Close Ties With Truck Driver’s Compensable Physical Injuries
Dec 23, 2011

North Carolina Teacher’s Tort Action Against Principal Who Prankishly Sprayed Her in Face With Fire Extinguisher May Move Forward

In a split decision, the Court of Appeals of North Carolina, in Trivette v. Yount, 2011 N.C. App. LEXIS 2598 (Dec. 20, 2011), has affirmed an order of a state...

North Carolina Teacher’s Tort Action Against Principal Who Prankishly Sprayed Her in Face With Fire Extinguisher May Move Forward North Carolina Teacher’s Tort Action Against Principal Who Prankishly Sprayed Her in Face With Fire Extinguisher May Move Forward
Dec 22, 2011

North Carolina Worker Injured While Retrieving Paycheck Denied Benefits Under “Going and Coming” Rule

A North Carolina appellate court, in Quiroz v. Metropols Statuary, Inc., 2011 N.C. App. LEXIS 2619 (Dec. 20, 2011), recently affirmed a decision by the state’s Industrial Commission that had...

North Carolina Worker Injured While Retrieving Paycheck Denied Benefits Under “Going and Coming” Rule North Carolina Worker Injured While Retrieving Paycheck Denied Benefits Under “Going and Coming” Rule
Dec 21, 2011

Arkansas Court Affirms Commission’s Order Requiring Claimant’s Attorney to Receive Half of Fee Over Nine-Year Period

The Court of Appeals of Arkansas has affirmed a determination by the state’s Workers’ Compensation Commission that ruled that a claimant’s attorney must receive one-half the allowed attorney’s fee in...

Arkansas Court Affirms Commission’s Order Requiring Claimant’s Attorney to Receive Half of Fee Over Nine-Year Period Arkansas Court Affirms Commission’s Order Requiring Claimant’s Attorney to Receive Half of Fee Over Nine-Year Period
Dec 20, 2011

Michigan Governor Poised to Sign Significant Workers’ Compensation Legislation

Indications are that Michigan Governor Rick Snyder will soon sign legislation that makes significant modifications to the state’s workers’ compensation law. H.B. 5002, introduced by state Representative Brad Jacobsen (R-Oxford),...

Michigan Governor Poised to Sign Significant Workers’ Compensation Legislation Michigan Governor Poised to Sign Significant Workers’ Compensation Legislation

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...