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Aug 20, 2026

Issue Commentary: Iowa Looks at Vaccine‑Injury Compensability—and Leaves the Real Question for Another Day

Driscoll Agrees with the Larson Standard, Then Affirms Without Needing It The Iowa Court of Appeals has affirmed the denial of workers’ compensation benefits to a city employee who developed...

Issue Commentary: Iowa Looks at Vaccine‑Injury Compensability—and Leaves the Real Question for Another Day Issue Commentary: Iowa Looks at Vaccine‑Injury Compensability—and Leaves the Real Question for Another Day
Aug 20, 2026

Issue Commentary: Iowa Looks at Vaccine‑Injury Compensability—and Leaves the Real Question for Another Day

Driscoll Agrees with the Larson Standard, Then Affirms Without Needing It The Iowa Court of Appeals has affirmed the denial of workers’ compensation benefits to a city employee who developed...

Issue Commentary: Iowa Looks at Vaccine‑Injury Compensability—and Leaves the Real Question for Another Day Issue Commentary: Iowa Looks at Vaccine‑Injury Compensability—and Leaves the Real Question for Another Day
Aug 19, 2026

VA: One Basket, Two Injuries—and Only One Compensable Accident

In *Sairafianpour v. Loudoun County Public Schools*, 2026 Va. App. LEXIS 430 (Aug. 11, 2026), the Court of Appeals of Virginia affirmed a Workers’ Compensation Commission decision awarding medical benefits...

VA: One Basket, Two Injuries—and Only One Compensable Accident VA: One Basket, Two Injuries—and Only One Compensable Accident
Aug 17, 2026

UT Supreme Court Affirms PTD Award—and Rejects Employer’s Claim to Employee’s Debt-Collection Settlement

In Granite School District v. Young, 2026 UT 29, 2026 Utah LEXIS 113 (Aug. 13, 2026), the Utah Supreme Court affirmed an award of permanent total disability benefits to a...

UT Supreme Court Affirms PTD Award—and Rejects Employer’s Claim to Employee’s Debt-Collection Settlement UT Supreme Court Affirms PTD Award—and Rejects Employer’s Claim to Employee’s Debt-Collection Settlement

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Aug 15, 2013

Pennsylvania: 5-Minute Deviation Defeated Workers’ Comp Claim

Some years ago, my mentor, Arthur Larson, when commenting upon the issue of deviations within the workplace, wrote that courts generally recognize “that human beings do not run on tracks...

Pennsylvania: 5-Minute Deviation Defeated Workers’ Comp Claim Pennsylvania: 5-Minute Deviation Defeated Workers’ Comp Claim
Aug 7, 2013

Ninth Circuit Construes Longshore Act’s Intoxication Defense Provisions

The Longshore Act provides that no compensation shall be payable if the injury “was occasioned solely by the intoxication of the employee” [33 U.S.C.S. § 903(c), emphasis added]. The Ninth...

Ninth Circuit Construes Longshore Act’s Intoxication Defense Provisions Ninth Circuit Construes Longshore Act’s Intoxication Defense Provisions
Jul 27, 2013

California: Legal Secretary’s IIED Claim Against Attorney and Firm Related to Pornographic Emails May Proceed

In an unpublished decision, Elster v. Fishman, 2013 Cal. App. Unpub. LEXIS 5158 (July 22, 2013) [check Cal. Rules of Court, Rule 8.1115(a) regarding rules related to citation], a California...

California: Legal Secretary’s IIED Claim Against Attorney and Firm Related to Pornographic Emails May Proceed California: Legal Secretary’s IIED Claim Against Attorney and Firm Related to Pornographic Emails May Proceed
Jul 14, 2013

Note to Employers and Carriers: Don’t Give Up Too Early in Cases Involving Preexisting Disease or Condition

Eggshell Skulls There’s a rule most of us learned early on in the first semester of Torts in law school: that there is ordinarily no allowance for an already weakened...

Note to Employers and Carriers: Don’t Give Up Too Early in Cases Involving Preexisting Disease or Condition Note to Employers and Carriers: Don’t Give Up Too Early in Cases Involving Preexisting Disease or Condition
Jul 3, 2013

Missouri Governor Vetoes Bill That Would Have Established State-Wide Database of Comp Claims (and Claimants)

Yesterday (July 2), Governor Jay Nixon vetoed legislation [Senate Bill 34] that would have permitted created a state-run database system that would have contained basic information about workers’ compensation claims...

Missouri Governor Vetoes Bill That Would Have Established State-Wide Database of Comp Claims (and Claimants) Missouri Governor Vetoes Bill That Would Have Established State-Wide Database of Comp Claims (and Claimants)
Jun 28, 2013

Vermont: AMA Guides Are Mandatory for Impairment Rating Purposes–Not Diagnosis of Condition Itself

The Supreme Court of Vermont, in a split decision, recently held that while the AMA Guides (5th Ed.) are determinative with respect to “any determination of the existence and degree...

Vermont: AMA Guides Are Mandatory for Impairment Rating Purposes–Not Diagnosis of Condition Itself Vermont: AMA Guides Are Mandatory for Impairment Rating Purposes–Not Diagnosis of Condition Itself
Jun 10, 2013

Ohio: Court Reverses Award For Facial Disfigurement Where Commission’s Findings Were Inadequate Under Statute

An Ohio appellate court recently reversed an award by the state’s Industrial Commission that allowed a claimant $4,000 of additional compensation for facial disfigurement under Ohio Rev. Code § 4123.57(B),...

Ohio: Court Reverses Award For Facial Disfigurement Where Commission’s Findings Were Inadequate Under Statute Ohio: Court Reverses Award For Facial Disfigurement Where Commission’s Findings Were Inadequate Under Statute
Jun 10, 2013

Connecticut: Special Statute Providing Benefits to Police Officers and Firefighters Injured During “Commute” Did Not Apply to Injury in Officer’s Driveway

The basic “going and coming” rule, in effect in the vast majority of jurisdictions, is that for an employee having fixed hours and place of work, injuries sustained going to...

Connecticut: Special Statute Providing Benefits to Police Officers and Firefighters Injured During “Commute” Did Not Apply to Injury in Officer’s Driveway Connecticut: Special Statute Providing Benefits to Police Officers and Firefighters Injured During “Commute” Did Not Apply to Injury in Officer’s Driveway
Jun 5, 2013

Ohio: Supreme Court Reiterates that Mental Injury Must Be Caused By, and Not Merely Contemporaneous With, Physical Injury To Support Comp Claim

In a divided decision affirming a ruling last year by a state intermediate appellate court, the Supreme Court of Ohio has reiterated that in order for a mental condition (here...

Ohio: Supreme Court Reiterates that Mental Injury Must Be Caused By, and Not Merely Contemporaneous With, Physical Injury To Support Comp Claim Ohio: Supreme Court Reiterates that Mental Injury Must Be Caused By, and Not Merely Contemporaneous With, Physical Injury To Support Comp Claim
Jun 4, 2013

Nebraska: High Court Affirms Dismissal of Intentional Tort Action Filed Against Employer That Violated Multiple OSHA Regulations; Action Barred by Exclusive Remedy Defense

The Supreme Court of Nebraska recently affirmed a decision of a county district court that had dismissed a tort action filed against the defendant-employer by the estate of an employee...

Nebraska: High Court Affirms Dismissal of Intentional Tort Action Filed Against Employer That Violated Multiple OSHA Regulations; Action Barred by Exclusive Remedy Defense Nebraska: High Court Affirms Dismissal of Intentional Tort Action Filed Against Employer That Violated Multiple OSHA Regulations; Action Barred by Exclusive Remedy Defense
Jun 3, 2013

Durham, NC: Recovering from Appendicitis

As a number of my friends and colleagues already know, I’ve been out of commission for the past nine days.  I underwent surgery eight days ago for a ruptured appendix....

Durham, NC: Recovering from Appendicitis Durham, NC: Recovering from Appendicitis
May 22, 2013

Iowa: Injuries Sustained in Janitor’s Idiopathic Fall Found Compensable

Reversing a decision by a state trial court that had, in turn, reversed an award of workers’ compensation benefits in favor of a seventy-nine-year-old part-time janitor who had suffered an...

Iowa: Injuries Sustained in Janitor’s Idiopathic Fall Found Compensable Iowa: Injuries Sustained in Janitor’s Idiopathic Fall Found Compensable

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