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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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Oct 8, 2013

U.S. Supreme Court Will Not Hear Hutterite Colony’s Religious Exclusion Argument

Yesterday, the United States Supreme Court indicated that it would not hear a Montana Hutterite Colony’s argument that a 2009 amendment to a state statute [§ 39–71–307, MCA] violated the...

U.S. Supreme Court Will Not Hear Hutterite Colony’s Religious Exclusion Argument U.S. Supreme Court Will Not Hear Hutterite Colony’s Religious Exclusion Argument
Oct 1, 2013

Alabama: Work-Product Rule Protects Post-Injury Accident Report from Discovery

Last Friday, a divided Supreme Court of Alabama, applying the work-product rule, determined that a post-accident investigation report, conducted and prepared by an employer’s safety director and a co-worker and...

Alabama: Work-Product Rule Protects Post-Injury Accident Report from Discovery Alabama: Work-Product Rule Protects Post-Injury Accident Report from Discovery
Sep 29, 2013

Employers Face Possible Liability in “Pretaliatory” Discharge Cases

The great majority of jurisdictions that have dealt with the issue, either by decision or statute, recognize the tort of retaliatory discharge for filing a workers compensation claim [see Larson’s...

Employers Face Possible Liability in “Pretaliatory” Discharge Cases Employers Face Possible Liability in “Pretaliatory” Discharge Cases
Sep 27, 2013

CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court

In a decision officially to be released on Tuesday (October 1), the Supreme Court of Connecticut has affirmed a decision of the state’s Workers’ Compensation Review Board that in turn...

CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court
Sep 27, 2013

6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola

A divided en banc panel of the Sixth Circuit Court of Appeals has reversed a decision by a three-judge panel of the same Circuit Court that had allowed a RICO...

6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola 6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola
Sep 19, 2013

Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails

Extensively quoting from Larson’s Workers’ Compensation Law and reiterating the state’s two-prong test to invoke the so-called “dual capacity doctrine” as an exception to the exclusive remedy provided by the...

Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails
Sep 18, 2013

Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000

In Ohio, like most jurisdictions, an employer or carrier that provides an injured worker with workers’ compensation benefits enjoys a subrogation interest, to the extent of such payment, in any...

Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000 Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000
Sep 14, 2013

Illinois: Workers’ Comp’s “Traveling Employee” Rule May Not Be Expanded to Tort Arena

Under workers’ compensation law’s so-called “going and coming” rule, for an employee having fixed hours and place of work, injuries sustained en route to or from the workplace are generally...

Illinois: Workers’ Comp’s “Traveling Employee” Rule May Not Be Expanded to Tort Arena Illinois: Workers’ Comp’s “Traveling Employee” Rule May Not Be Expanded to Tort Arena
Sep 9, 2013

Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee

In the determination of any contested workers’ compensation claim, Hawaii favors the claimant with a presumption of compensability [HRS § 386–85]. Construing that presumption, a state appellate court recently affirmed...

Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee
Sep 7, 2013

Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable

Illustrating the significant deference given to the Commission’s factual findings, an Arkansas appellate court recently affirmed the denial of benefits to an employee who sustained injuries when he slipped and...

Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable
Sep 4, 2013

Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits

In many states, the death benefit owed to a surviving spouse is commuted, sometimes at a significant discount, if the surviving spouse remarries. The Missouri statute, § 287.240(4)(a) R.S. Mo.,...

Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits
Aug 30, 2013

Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason

An Oregon appellate court recently affirmed a decision by the state’s Workers’ Compensation Board that concluded claimant’s subsistence and travel pay were “wages” for purposes of determining claimant’s TTD benefits...

Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason

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