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Mar 5, 2026

Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage

In Motors v. Bayly (Red House Motors d/b/a Bayly’s Garage), 2026 Del. LEXIS 92 (Mar. 2, 2026), the Delaware Supreme Court reversed a Superior Court decision that the high court...

Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage
Mar 3, 2026

Florida Court Invalidates Rules Expanding “Absolute Choice” Pharmacy Provision

In Publix Super Markets, Inc. v. Department of Financial Services, 2026 Fla. App. LEXIS 1469 (Fla. 1st DCA Feb. 25, 2026), the First District Court of Appeal recently held that...

Florida Court Invalidates Rules Expanding “Absolute Choice” Pharmacy Provision Florida Court Invalidates Rules Expanding “Absolute Choice” Pharmacy Provision
Feb 26, 2026

Florida Court: IME Report Is Not a “Prescription” for Attendant Care

The Florida First District Court of Appeal has reversed an award of 24-hour attendant care benefits where the only “prescription” supporting the award appeared in an Independent Medical Examiner’s report...

Florida Court: IME Report Is Not a “Prescription” for Attendant Care Florida Court: IME Report Is Not a “Prescription” for Attendant Care
Feb 24, 2026

Issue Commentary: Where PA Worker’s Injury is Compensable, Does That Automatically Mean Co-Employee is Immune from Tort Liability?

PA Supreme Court Addresses Scope of Co-Employee Immunity In Brown v. Gaydos, 2026 Pa. LEXIS 267 (Pa. Feb. 18, 2026), a divided Pennsylvania Supreme Court affirmed the Superior Court’s reversal...

Issue Commentary: Where PA Worker’s Injury is Compensable, Does That Automatically Mean Co-Employee is Immune from Tort Liability? Issue Commentary: Where PA Worker’s Injury is Compensable, Does That Automatically Mean Co-Employee is Immune from Tort Liability?

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Dec 5, 2012

Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative

Reversing the state’s Court of Appeals, the Supreme Court of Georgia has ruled that an employee who filed a claim under the state’s Workers’ Compensation Act, must authorize her treating...

Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative Georgia: Claimant Required to Consent to Ex Parte Communications Between Treating Physician and Employer or Employer’s Representative
Nov 23, 2012

Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded

An Arizona appellate court recently held, as a matter of law, that a workers’ compensation claimant who expressed an intention to record an independent medical examination (“IME”), in the absence...

Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded Arizona: Carrier May Not Suspend Benefits Where Claimant Indicates IME Will Be Recorded
Nov 21, 2012

LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell

Under the Longshore and Harbor Workers’ Compensation Act (“LHWCA”), no compensation is payable “if the injury was occasioned solely by the intoxication of the employee” [see 33 U.S.C. § 903(c)]....

LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell LHWCA: Ninth Circuit Agrees that Injury Was Caused By Intoxication, Not Concrete and Metal Slab Onto Which Claimant Fell
Nov 19, 2012

Getting Hurt “On the Job”

As I’ve mentioned in my last several posts, a bit more than a week ago, I enjoyed being part of three panel discussions at the 21st Annual National Workers’ Compensation...

Getting Hurt “On the Job” Getting Hurt “On the Job”
Nov 16, 2012

Oklahoma: Supreme Court Reverses Court of Appeals in “Substantially Certain” Case

In what will likely be one of the last cases to be heard under Oklahoma’s court-crafted version of the “substantially certain” rule [see Larson’s Workers’ Compensation Law, § 103.04[2][e]] that...

Oklahoma: Supreme Court Reverses Court of Appeals in “Substantially Certain” Case Oklahoma: Supreme Court Reverses Court of Appeals in “Substantially Certain” Case
Nov 15, 2012

Indiana: Recent Decision Shows the General Strength of the Exclusivity Defense

Last week, at the 21st Annual National Workers’ Compensation and Disability Conference® & Expo, in Las Vegas, I was happy to be part of a panel discussion regarding the “Future...

Indiana: Recent Decision Shows the General Strength of the Exclusivity Defense Indiana: Recent Decision Shows the General Strength of the Exclusivity Defense
Nov 14, 2012

New York: Failure to Disclose Injury in Professional Boxing Match Causes Forfeiture of Future Disability Rights

A New York appellate court, in Martinez v. Lefrak City Mngmt., 2012 N.Y. App. Div. LEXIS 7330 (3rd Dept., Nov. 8, 2012), recently affirmed a finding by the state’s Workers’...

New York: Failure to Disclose Injury in Professional Boxing Match Causes Forfeiture of Future Disability Rights New York: Failure to Disclose Injury in Professional Boxing Match Causes Forfeiture of Future Disability Rights
Nov 9, 2012

Live From Las Vegas!

4:30 PM (Pacific) I’m sorry that it’s been a couple of weeks since my last post. It isn’t that my mind has been on matters other than workers’ compensation. In...

Live From Las Vegas! Live From Las Vegas!
Oct 24, 2012

New York: Extraordinary Duties at Grocery Store on Super Bowl Sunday Mean Employee’s Death is Compensable

A New York appellate court recently agreed with the state’s Workers’ Compensation Board that the death of a grocery store employee was causally related to the employment where evidence showed...

New York: Extraordinary Duties at Grocery Store on Super Bowl Sunday Mean Employee’s Death is Compensable New York: Extraordinary Duties at Grocery Store on Super Bowl Sunday Mean Employee’s Death is Compensable
Oct 23, 2012

Iowa: Court Approves “Uneven” Split of Death Benefits Between American and Honduran Dependents of Deceased Undocumented Worker

The Court of Appeals of Iowa, in Carter v. Alter Trading Corp., 2012 Iowa App. LEXIS 879 (Oct. 17, 2012), applying the state’s “equitable” apportionment of workers’ compensation death benefits...

Iowa: Court Approves “Uneven” Split of Death Benefits Between American and Honduran Dependents of Deceased Undocumented Worker Iowa: Court Approves “Uneven” Split of Death Benefits Between American and Honduran Dependents of Deceased Undocumented Worker
Oct 20, 2012

Iowa: Court Finds Evidence Does Not Support Requiring Employer to Bear Expense of Gastric Bypass Surgery

Because an injured worker offered no evidence, other than her own testimony, that her gastric bypass surgery had been beneficial to her work-related injury, it was error to find the...

Iowa: Court Finds Evidence Does Not Support Requiring Employer to Bear Expense of Gastric Bypass Surgery Iowa: Court Finds Evidence Does Not Support Requiring Employer to Bear Expense of Gastric Bypass Surgery
Oct 19, 2012

Illinois: Injured Employee’s “Dual Capacity/Dual Persona” Claim Against Corporate Officers of Employer Fails

In a recent decision by the Appellate Court of Illinois, Second District, Hilgart v. 210 Mittel Drive Partnership, 2012 Ill. App. LEXIS 850 (Oct. 17, 2012), the court held that...

Illinois: Injured Employee’s “Dual Capacity/Dual Persona” Claim Against Corporate Officers of Employer Fails Illinois: Injured Employee’s “Dual Capacity/Dual Persona” Claim Against Corporate Officers of Employer 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