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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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May 9, 2013

Oklahoma: Workers’ Compensation “Opt-Out” Provisions Become Law

On Tuesday (May 7), Oklahoma Governor Mary Fallin signed into law Senate Bill 1062, a legislative piece that purports to reform the state’s workers’ compensation system in two broad fashions:...

Oklahoma: Workers’ Compensation “Opt-Out” Provisions Become Law Oklahoma: Workers’ Compensation “Opt-Out” Provisions Become Law
Apr 29, 2013

Montana: Carrier’s Decision to Stop Paying For Pain Medication Did Not Justify Attorney’s Fee Award Where Decision Was Based On Prior Decision of Workers’ Compensation Court

Stressing that “reasonableness” is a question of fact and that the review the Workers’ Compensation Court’s findings of fact were to be affirmed if supported by substantial credible evidence, the...

Montana: Carrier’s Decision to Stop Paying For Pain Medication Did Not Justify Attorney’s Fee Award Where Decision Was Based On Prior Decision of Workers’ Compensation Court Montana: Carrier’s Decision to Stop Paying For Pain Medication Did Not Justify Attorney’s Fee Award Where Decision Was Based On Prior Decision of Workers’ Compensation Court
Apr 19, 2013

Rhode Island: Utilizing “Street-Peril” or Street Risk Doctrine, Supreme Court Reverses Denial of Claim by Verizon Employee Assaulted by Random Stranger

The Supreme Court of Rhode Island recently quashed a decree by the state’s Workers’ Compensation Court Appellate Division that in turn had affirmed a denial of workers’ compensation benefits to...

Rhode Island: Utilizing “Street-Peril” or Street Risk Doctrine, Supreme Court Reverses Denial of Claim by Verizon Employee Assaulted by Random Stranger Rhode Island: Utilizing “Street-Peril” or Street Risk Doctrine, Supreme Court Reverses Denial of Claim by Verizon Employee Assaulted by Random Stranger
Apr 17, 2013

New Mexico: Late Filing of Death Benefits Claim May Be Excused Where Delay Was Due, In Part, to Actions of Employer

The Supreme Court of New Mexico recently held that a death benefits claim filed by the widow of an off-duty police officer, who drowned while rescuing a twelve-year-old boy from...

New Mexico: Late Filing of Death Benefits Claim May Be Excused Where Delay Was Due, In Part, to Actions of Employer New Mexico: Late Filing of Death Benefits Claim May Be Excused Where Delay Was Due, In Part, to Actions of Employer
Apr 16, 2013

Minnesota: Costs to Modify Injured Worker’s Residence to Allow For Installation of Lift System Was Limited to Statutory Max of $60K

Installation of a lift system to enable paraplegic to transfer to and from her wheelchair more safely and to live more independently were remodeling costs subject to the $60,000 limit...

Minnesota: Costs to Modify Injured Worker’s Residence to Allow For Installation of Lift System Was Limited to Statutory Max of $60K Minnesota: Costs to Modify Injured Worker’s Residence to Allow For Installation of Lift System Was Limited to Statutory Max of $60K
Apr 9, 2013

Louisiana: Police Officer Fails To Establish Acute Appendicitis Claim Was Connected to Fall at Police Station

A Louisiana appellate court recently affirmed a finding by the Office of Workers’ Compensation that granted an employer police department’s motion for summary judgment regarding a claim filed by a...

Louisiana: Police Officer Fails To Establish Acute Appendicitis Claim Was Connected to Fall at Police Station Louisiana: Police Officer Fails To Establish Acute Appendicitis Claim Was Connected to Fall at Police Station
Apr 8, 2013

Montana’s Hutterite Colony Seeks Review by U.S. Supreme Court of Decision Requiring it to Provide Workers’ Compensation Coverage for Colony’s Workers

On April 1, the Hutterite Colony, a small religious sect in Montana, asked the United States Supreme Court to review and overturn a decision by the Supreme Court of Montana...

Montana’s Hutterite Colony Seeks Review by U.S. Supreme Court of Decision Requiring it to Provide Workers’ Compensation Coverage for Colony’s Workers Montana’s Hutterite Colony Seeks Review by U.S. Supreme Court of Decision Requiring it to Provide Workers’ Compensation Coverage for Colony’s Workers
Apr 8, 2013

Arkansas: Health Care Technician Fails to Establish Corneal Ulcer Was Associated With Work-Related Urine Splash

An Arkansas appellate court recently affirmed a decision denying a claim filed by a patient-care technician who contended that her corneal ulcer resulted from or was exacerbated by a workplace...

Arkansas: Health Care Technician Fails to Establish Corneal Ulcer Was Associated With Work-Related Urine Splash Arkansas: Health Care Technician Fails to Establish Corneal Ulcer Was Associated With Work-Related Urine Splash
Mar 29, 2013

Virginia: Employee’s Refusal of Second Knee Surgery Justified

On Tuesday, a Virginia appellate court affirmed a decision of the state’s Workers’ Compensation Commission that reinstated disability benefits to a convenience store employee who refused to undergo recommended surgery–a...

Virginia: Employee’s Refusal of Second Knee Surgery Justified Virginia: Employee’s Refusal of Second Knee Surgery Justified
Mar 27, 2013

Maine: Employer Not Entitled to Offset Incapacity Benefits Against Specific Loss Award for Amputation

The Supreme Judicial Court of Maine recently reversed an award by the state’s Workers’ Compensation Board that had granted an employee specific loss benefits for the amputation of a finger,...

Maine: Employer Not Entitled to Offset Incapacity Benefits Against Specific Loss Award for Amputation Maine: Employer Not Entitled to Offset Incapacity Benefits Against Specific Loss Award for Amputation
Mar 25, 2013

New York: No Death Benefits Awarded Where Work-Related Heart Attack Occurred 24 Years Earlier

A New York appellate court recently affirmed a finding by the state’s Workers’ Compensation Board that ruled that the death of claimant’s husband was not causally related to his employment...

New York: No Death Benefits Awarded Where Work-Related Heart Attack Occurred 24 Years Earlier New York: No Death Benefits Awarded Where Work-Related Heart Attack Occurred 24 Years Earlier
Mar 23, 2013

Ohio: Appellate Court Distinguishes Case from Earlier Moorehead Decision: No Loss of Use of Trucker’s Legs Where He May Have Survived Wreck for Brief Period of Time

An Ohio appellate court recently affirmed a decision by the state’s Industrial Commission that had denied additional workers’ compensation benefits for the scheduled loss of use of both of a...

Ohio: Appellate Court Distinguishes Case from Earlier Moorehead Decision: No Loss of Use of Trucker’s Legs Where He May Have Survived Wreck for Brief Period of Time Ohio: Appellate Court Distinguishes Case from Earlier Moorehead Decision: No Loss of Use of Trucker’s Legs Where He May Have Survived Wreck for Brief Period of Time

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