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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
Mar 25, 2025

CT Supreme Court: Temporary Partial Benefits May Continue After MMI

In what I think is an unprecedented decision, the Connecticut Supreme Court has held that a workers’ compensation commissioner may award ongoing temporary partial incapacity benefits even after a claimant...

CT Supreme Court: Temporary Partial Benefits May Continue After MMI CT Supreme Court: Temporary Partial Benefits May Continue After MMI

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Dec 17, 2011

For Second Time in Eight Months, Arkansas Court Sends Case Back to Workers’ Compensation Commission to Determine if Claimant Successfully Rebutted Statutory Presumption Related to Alleged Methamphetamine Use

It’s axiomatic that in virtually all workers’ compensation cases it is the fact-finder–the Industrial Commission, Appeals Board, or the hearing officer–who must pass upon the credibility of witnesses; the appellate...

For Second Time in Eight Months, Arkansas Court Sends Case Back to Workers’ Compensation Commission to Determine if Claimant Successfully Rebutted Statutory Presumption Related to Alleged Methamphetamine Use For Second Time in Eight Months, Arkansas Court Sends Case Back to Workers’ Compensation Commission to Determine if Claimant Successfully Rebutted Statutory Presumption Related to Alleged Methamphetamine Use
Dec 16, 2011

Pennsylvania Worker’s “Dual Persona” Tort Action Against Employer Fails

Since the enactment of the first state workers’ compensation laws one hundred years ago, exclusive remedy provisions within state acts have been a core component of the workers’ compensation “bargain.”...

Pennsylvania Worker’s “Dual Persona” Tort Action Against Employer Fails Pennsylvania Worker’s “Dual Persona” Tort Action Against Employer Fails
Dec 15, 2011

Michigan Plaintiff’s Retaliatory Discharge Action Fails

Finding that a discharged plaintiff had failed to establish that she engaged in a protected activity under the Worker’s Disability Compensation Act (WDCA), MCL 418.101 et seq., failed to demonstrate...

Michigan Plaintiff’s Retaliatory Discharge Action Fails Michigan Plaintiff’s Retaliatory Discharge Action Fails
Dec 14, 2011

Nebraska High Court Nixes Pre-Employment Questionnaire “Misrepresentation” Defense

Holding that its decades-old adoption of the equitable misrepresentation defense in Hilt Truck Lines, Inc. v. Jones, 204 Neb. 115, 281 N.W.2d 399 (1979) was “clearly erroneous,” the Supreme Court...

Nebraska High Court Nixes Pre-Employment Questionnaire “Misrepresentation” Defense Nebraska High Court Nixes Pre-Employment Questionnaire “Misrepresentation” Defense

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...