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Jul 16, 2026

Personal Comfort Doctrine Reaches a Formal, Unpaid Break

PA Court Finds a 15-Minute Break’s Brevity Outweighs Its Formality The Commonwealth Court of Pennsylvania recently affirmed an award of workers’ compensation benefits to a pharmacy technician struck by a...

Personal Comfort Doctrine Reaches a Formal, Unpaid Break Personal Comfort Doctrine Reaches a Formal, Unpaid Break
Jul 14, 2026

Trucker’s Retaliation Claim Runs Aground in His Own Hay Field

Idaho Federal Court Finds Surveillance and a Full-Duty Release Defeat Workers' Comp Retaliatory Discharge Claim The U.S. District Court for the District of Idaho recently granted summary judgment for a...

Trucker’s Retaliation Claim Runs Aground in His Own Hay Field Trucker’s Retaliation Claim Runs Aground in His Own Hay Field
Jul 13, 2026

FL High Court Rejects Motive Requirement for Workplace Assault Claims

Risk-Exposure Evidence Alone Can Establish the Causal Link, Justices Hold Last Thursday, In a unanimous decision authored by Justice Muñiz, the Supreme Court of Florida held that a workplace assault...

FL High Court Rejects Motive Requirement for Workplace Assault Claims FL High Court Rejects Motive Requirement for Workplace Assault Claims
Jul 8, 2026

KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths

Supervisors Who Allegedly Blocked Exits Fell Outside the Workers’ Comp Act’s Exclusive Remedy The Kentucky Court of Appeals has revived tort claims brought by survivors of the December 2021 tornado...

KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths

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Oct 25, 2013

Florida: First DCA Certifies Constitutional Question After Affirming $165 Fee for 107 Hours of Work

Reluctantly affirming a decision by a Judge of Compensation Claims that had awarded claimant’s counsel an attorney’s fee of only $164.54 for 107.2 hours of legal work reasonably necessary to...

Florida: First DCA Certifies Constitutional Question After Affirming $165 Fee for 107 Hours of Work Florida: First DCA Certifies Constitutional Question After Affirming $165 Fee for 107 Hours of Work
Oct 24, 2013

Virginia: Self-Treatment by Rehab Professor Nixes Benefits for Subsequent Injuries

While Scripture may say, “Physician, heal thyself” [Luke 4:23, King James Version], that advice should apparently be avoided by professors of rehabilitation counseling. In a case replete with irony, the...

Virginia: Self-Treatment by Rehab Professor Nixes Benefits for Subsequent Injuries Virginia: Self-Treatment by Rehab Professor Nixes Benefits for Subsequent Injuries
Oct 23, 2013

Illinois: Excess Coverage Policies Enjoy Same Exclusion From Guaranty Fund “Cap” on Payment as Primary Coverage Policies

Like every other state, Illinois has established an insolvent insurance fund–the Illinois Insurance Guaranty Fund–that steps in, under appropriate circumstances, to pay claims when an insurance company authorized to transact...

Illinois: Excess Coverage Policies Enjoy Same Exclusion From Guaranty Fund “Cap” on Payment as Primary Coverage Policies Illinois: Excess Coverage Policies Enjoy Same Exclusion From Guaranty Fund “Cap” on Payment as Primary Coverage Policies
Oct 21, 2013

Pennsylvania: Massage Therapy By LPN Held to be Compensable Expense

A Pennsylvania appellate court, reversing a decision of the state’s Workers’ Compensation Appeal Board, recently held that since a licensed practical nurse (LPN) was a “health care provider” under §...

Pennsylvania: Massage Therapy By LPN Held to be Compensable Expense Pennsylvania: Massage Therapy By LPN Held to be Compensable Expense
Oct 15, 2013

Wyoming: Employee’s Intentional Tort Action Against Supervisors Fails

Construing the intentional injury exception to the exclusive remedy provisions of the Wyoming Workers’ Compensation Act [Wyo. Stat. Ann. § 27–14–104(a) (LexisNexis 2013)], the state’s Supreme Court recently affirmed a...

Wyoming: Employee’s Intentional Tort Action Against Supervisors Fails Wyoming: Employee’s Intentional Tort Action Against Supervisors Fails
Oct 13, 2013

Louisiana: Boilermaker’s 39-Day Work Schedule, With One Day Off, Found to Cause Stroke

In Louisiana, when an employee seeks to recover workers’ compensation benefits for a heart-related or perivascular injury, he or she must prove, by clear and convincing evidence, that: (i) The...

Louisiana: Boilermaker’s 39-Day Work Schedule, With One Day Off, Found to Cause Stroke Louisiana: Boilermaker’s 39-Day Work Schedule, With One Day Off, Found to Cause Stroke
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

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