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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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Mar 19, 2013

Ohio: Truck Driver’s Termination For Causing Accident in Which He Sustained Injuries Does Not Disqualify Him From TTD Benefits

In State ex rel. Haddox v. Industrial Comm’n, 2013 Ohio 794, 2013 Ohio LEXIS 618 (Mar. 12, 2013), the Supreme Court of Ohio recently affirmed an appellate court’s decision that...

Ohio: Truck Driver’s Termination For Causing Accident in Which He Sustained Injuries Does Not Disqualify Him From TTD Benefits Ohio: Truck Driver’s Termination For Causing Accident in Which He Sustained Injuries Does Not Disqualify Him From TTD Benefits
Feb 24, 2013

Washington: School Custodian’s Tort Claim Against Employer for PTSD Resulting From Clean-up Duties Following Student’s Suicide Is Barred by Exclusivity

Last Thursday, a Washington state appellate court affirmed the dismissal of a civil action filed by a school custodian against her employer, a school district and its superintendent, alleging intentional...

Washington: School Custodian’s Tort Claim Against Employer for PTSD Resulting From Clean-up Duties Following Student’s Suicide Is Barred by Exclusivity Washington: School Custodian’s Tort Claim Against Employer for PTSD Resulting From Clean-up Duties Following Student’s Suicide Is Barred by Exclusivity
Feb 23, 2013

New York: Mechanic’s Fatal Heart Attack Sustained on Employer’s Premises, But After Work Shift, Held Not Compensable

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

New York: Mechanic’s Fatal Heart Attack Sustained on Employer’s Premises, But After Work Shift, Held Not Compensable New York: Mechanic’s Fatal Heart Attack Sustained on Employer’s Premises, But After Work Shift, Held Not Compensable
Feb 16, 2013

South Carolina: Supreme Court Adopts Larson’s “Dual Persona” Doctrine

Answering a question certified to it by the U.S. District Court for the District of South Carolina, the Supreme Court of South Carolina, in Mendenall v. Anderson Hardwood Floors, Inc.,...

South Carolina: Supreme Court Adopts Larson’s “Dual Persona” Doctrine South Carolina: Supreme Court Adopts Larson’s “Dual Persona” Doctrine
Feb 8, 2013

North Carolina: Intentional Tort Action Against Wal-Mart Related to Death of Wal-Mart “Greeter” Barred by Exclusivity

On Tuesday, the Court of Appeals of North Carolina affirmed a trial court’s order granting various defendants’ motions for summary judgment on exclusivity grounds in a wrongful death action filed...

North Carolina: Intentional Tort Action Against Wal-Mart Related to Death of Wal-Mart “Greeter” Barred by Exclusivity North Carolina: Intentional Tort Action Against Wal-Mart Related to Death of Wal-Mart “Greeter” Barred by Exclusivity
Feb 5, 2013

Kentucky: Convenience Store Worker’s Access to Premises and Security Codes Provides Causal Link Between His Murder and the Employment

The Court of Appeals of Kentucky recently affirmed an award of death benefits to the administratrix of the estate of a deceased convenience store worker (“Pendleton”) who was found after...

Kentucky: Convenience Store Worker’s Access to Premises and Security Codes Provides Causal Link Between His Murder and the Employment Kentucky: Convenience Store Worker’s Access to Premises and Security Codes Provides Causal Link Between His Murder and the Employment
Jan 24, 2013

Florida: Court Reverses Injured Worker’s $2.7 Million Verdict Against Employer: Injury Was Not “Virtually Certain”

In a workers’ compensation immunity case, the Court of Appeal of Florida (Fourth District) yesterday reversed a $2.7 million jury verdict and final judgment in favor of an employee who...

Florida: Court Reverses Injured Worker’s $2.7 Million Verdict Against Employer: Injury Was Not “Virtually Certain” Florida: Court Reverses Injured Worker’s $2.7 Million Verdict Against Employer: Injury Was Not “Virtually Certain”
Jan 21, 2013

Louisiana: Police Sergeant’s Short Trip to Headquarters To Get Cash From Credit Union Was Deviation From Employment; Injuries in Stairwell Not Compensable

A Louisiana appellate court recently affirmed the denial of a claim filed by a police sergeant who sustained injuries when he fell in a stairwell at Police Headquarters following a...

Louisiana: Police Sergeant’s Short Trip to Headquarters To Get Cash From Credit Union Was Deviation From Employment; Injuries in Stairwell Not Compensable Louisiana: Police Sergeant’s Short Trip to Headquarters To Get Cash From Credit Union Was Deviation From Employment; Injuries in Stairwell Not Compensable
Jan 7, 2013

Ohio: Appellate Court Affirms Award for PTSD in Spite of State’s Limiting Definition of “Injury”

An Ohio appellate court recently affirmed a trial court’s summary judgment in favor of a medical center clerk who had received an award of workers’ compensation benefits related to physical...

Ohio: Appellate Court Affirms Award for PTSD in Spite of State’s Limiting Definition of “Injury” Ohio: Appellate Court Affirms Award for PTSD in Spite of State’s Limiting Definition of “Injury”
Jan 4, 2013

Divided Supreme Court of Montana Says Statute Defining Religious Order as Employer (For Workers’ Compensation Purposes) is Not Unconstitutional

On the last day of 2012, and in a split decision, the Supreme Court of Montana reversed a trial court’s summary judgment decision that had earlier determined that the requirement...

Divided Supreme Court of Montana Says Statute Defining Religious Order as Employer (For Workers’ Compensation Purposes) is Not Unconstitutional Divided Supreme Court of Montana Says Statute Defining Religious Order as Employer (For Workers’ Compensation Purposes) is Not Unconstitutional
Jan 4, 2013

D.C. Circuit Court: Personal Representative’s Civil Action Against Employer for Negligent Provision of Firearm to Suicide Victim/Employee May Not Proceed

In a case with a number of interesting twists, the Court of Appeals for the D.C. Circuit recently affirmed a decision by a U.S. District Court that, in relevant part,...

D.C. Circuit Court: Personal Representative’s Civil Action Against Employer for Negligent Provision of Firearm to Suicide Victim/Employee May Not Proceed D.C. Circuit Court: Personal Representative’s Civil Action Against Employer for Negligent Provision of Firearm to Suicide Victim/Employee May Not Proceed
Dec 31, 2012

Missouri: Retaliatory Discharge Statute Requires Former Employee to Establish that Exercise of Rights Was Exclusive, Not Merely a Contributing, Factor in Firing

A Missouri appellate court recently affirmed a jury verdict in favor of a former employer on a former employee’s claim of retaliatory discharge and agreed that the former employee was...

Missouri: Retaliatory Discharge Statute Requires Former Employee to Establish that Exercise of Rights Was Exclusive, Not Merely a Contributing, Factor in Firing Missouri: Retaliatory Discharge Statute Requires Former Employee to Establish that Exercise of Rights Was Exclusive, Not Merely a Contributing, Factor in Firing

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