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Jun 2, 2026

Maine Supreme Court: Massachusetts Law Strips Staffing Client of Workers’ Compensation Immunity

Court Applies Massachusetts Law to Maine Injury, Rejects Immunity Defense in Multi-State Staffing Arrangement A New Hampshire contractor that likely would have enjoyed workers’ compensation immunity under Maine law lost...

Maine Supreme Court: Massachusetts Law Strips Staffing Client of Workers’ Compensation Immunity Maine Supreme Court: Massachusetts Law Strips Staffing Client of Workers’ Compensation Immunity
Jun 1, 2026

NY High Court Holds JIWA Bars Collateral Estoppel Effect of Pre-Enactment Workers’ Comp Decisions

New York’s Court of Appeals recently affirmed an Appellate Division order blocking defendants in a personal injury action from using a Workers’ Compensation Board causation determination as collateral estoppel, holding...

NY High Court Holds JIWA Bars Collateral Estoppel Effect of Pre-Enactment Workers’ Comp Decisions NY High Court Holds JIWA Bars Collateral Estoppel Effect of Pre-Enactment Workers’ Comp Decisions
May 27, 2026

Nebraska Supreme Court Affirms Denial of Death Benefits Where Work Injury Delayed Cancer Treatment

In a case involving a Nebraska truck driver-farm laborer whose treatment for metastatic cancer was allegedly postponed by complications associated with a compensable hip injury and its resulting treatment, the...

Nebraska Supreme Court Affirms Denial of Death Benefits Where Work Injury Delayed Cancer Treatment Nebraska Supreme Court Affirms Denial of Death Benefits Where Work Injury Delayed Cancer Treatment
May 26, 2026

NC Court of Appeals: Exclusivity Doctrine Bars Negligence Suit Following Workplace Stroke

A North Carolina district manager who suffered a stroke while preparing for the opening of a restaurant location—and who allegedly waited hours before coworkers summoned emergency assistance—may not pursue negligence...

NC Court of Appeals: Exclusivity Doctrine Bars Negligence Suit Following Workplace Stroke NC Court of Appeals: Exclusivity Doctrine Bars Negligence Suit Following Workplace Stroke

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Feb 27, 2014

Compromise and Settlement: May An Employer Include a Penalty Clause to Ward Off Further Vexatious Claims?

Each year I read–or at least scan–more than 1,500 workers’ compensation cases that make the appellate reporter system around the nation. As large as that number sounds, it’s really fewer...

Compromise and Settlement: May An Employer Include a Penalty Clause to Ward Off Further Vexatious Claims? Compromise and Settlement: May An Employer Include a Penalty Clause to Ward Off Further Vexatious Claims?
Feb 25, 2014

Ohio: Comatose Injured Worker’s Additional Claim for Loss of Vision and Hearing Fails

The Supreme Court of Ohio, reversing an earlier decision by an intermediate appellate court, recently affirmed the state Industrial Commission’s denial of a loss of vision and hearing claim under...

Ohio: Comatose Injured Worker’s Additional Claim for Loss of Vision and Hearing Fails Ohio: Comatose Injured Worker’s Additional Claim for Loss of Vision and Hearing Fails
Feb 25, 2014

Bariatric Surgery: Is it a Workers’ Compensation Medical Benefit?

Last week, I was very pleased to be a part of an Orlando, Florida risk management conference sponsored by Artex Risk Solutions. Along with two good friends and colleagues, Rebecca...

Bariatric Surgery: Is it a Workers’ Compensation Medical Benefit? Bariatric Surgery: Is it a Workers’ Compensation Medical Benefit?
Feb 17, 2014

Louisiana: Mileage Payment Does Not Bring EMT’s Travel Within the Employment; Going and Coming Rule Bars Claim

In Potier v. Acadian Ambulance Serv., Inc., 2014 La. App. LEXIS 347 (February 12, 2014), a Louisiana appellate court recently affirmed a decision by a state workers’ compensation judge that...

Louisiana: Mileage Payment Does Not Bring EMT’s Travel Within the Employment; Going and Coming Rule Bars Claim Louisiana: Mileage Payment Does Not Bring EMT’s Travel Within the Employment; Going and Coming Rule Bars Claim
Feb 17, 2014

NY: Employer Does Not Lose Exclusivity Defense in Contribution/Indemnification Case Because Employee was Undocumented Alien

N.Y. Work. Comp. Law § 11 bars third-party lawsuits for contribution and indemnification against an injured employee’s employer unless either (a) the employee suffered a “grave injury,” limited to death...

NY: Employer Does Not Lose Exclusivity Defense in Contribution/Indemnification Case Because Employee was Undocumented Alien NY: Employer Does Not Lose Exclusivity Defense in Contribution/Indemnification Case Because Employee was Undocumented Alien
Feb 14, 2014

NY Court: No Reopening Allowed in Established Claim re: Murdered Employee

Indicating that in New York there were two requisites for reopening a claim based on newly acquired evidence: (a) the application to reopen “must be made within a reasonable time...

NY Court: No Reopening Allowed in Established Claim re: Murdered Employee NY Court: No Reopening Allowed in Established Claim re: Murdered Employee
Feb 13, 2014

Idaho Shoe Lace Causes Compensable Herniated Disc

In a decision showing just how strongly the state’s workers’ compensation system separates the “arising out of” the employment component of the compensation formula from the “course of employment” component,...

Idaho Shoe Lace Causes Compensable Herniated Disc Idaho Shoe Lace Causes Compensable Herniated Disc
Feb 11, 2014

Texas Exclusive Remedy Provision Does Not Apply to Health Care Providers

The exclusive remedy provision of Tex. Lab. Code Ann. § 408.001(a) does not apply to health care providers, held a Texas appellate court recently, in Hand & Wrist Center of...

Texas Exclusive Remedy Provision Does Not Apply to Health Care Providers Texas Exclusive Remedy Provision Does Not Apply to Health Care Providers
Jan 20, 2014

Tennessee: Appellate Court Says Compensation Paid to Independent Contractors Should Have Been Considered in Computing Insured’s Comp Premiums

A Tennessee Department of Commerce and Insurance ruling–later upheld by a state trial court–that a company was not liable for additional workers’ compensation insurance premiums related to the earnings of...

Tennessee: Appellate Court Says Compensation Paid to Independent Contractors Should Have Been Considered in Computing Insured’s Comp Premiums Tennessee: Appellate Court Says Compensation Paid to Independent Contractors Should Have Been Considered in Computing Insured’s Comp Premiums
Jan 17, 2014

US: Establishing “Substantial Certainty” in Intentional Tort Cases is Difficult

Construing La. Rev. Stat. § 23:1032, which generally provides that workers’ compensation is the exclusive remedy of an employee injured within the course and scope of the employment unless the...

US: Establishing “Substantial Certainty” in Intentional Tort Cases is Difficult US: Establishing “Substantial Certainty” in Intentional Tort Cases is Difficult
Dec 28, 2013

South Carolina Supreme Court Says Nurse Anesthetist Was Employee, Not Independent Contractor

Reversing a decision by the state’s court of appeals, the Supreme Court of South Carolina recently held that direct evidence supported the Workers’ Compensation Commission’s original determination that a certified...

South Carolina Supreme Court Says Nurse Anesthetist Was Employee, Not Independent Contractor South Carolina Supreme Court Says Nurse Anesthetist Was Employee, Not Independent Contractor
Dec 24, 2013

Federal Judge in Phoenix Says RICO Case May Move Forward

A federal district court judge ruled yesterday that nine fire department employees may maintain a civil action they had filed under the Racketeer Influenced and Corrupt Organizations [RICO] Act against...

Federal Judge in Phoenix Says RICO Case May Move Forward Federal Judge in Phoenix Says RICO Case May Move Forward

New Comments

  • ramivou: They hid behind a flawed "reading" of this statute for a decade. I am glad the SC finally put an end to the misconception that it was a "first six months only" filing requirement, rather than an ongoing responsibility.
  • 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