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Mar 6, 2026

New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits

Every dollar spent on workers’ compensation falls into one of two broad categories: benefits paid to injured workers—medical care and wage replacement—and the costs of delivering those benefits. The second...

New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits
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

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Mar 6, 2025

Throwback Thursday: Guidry v. Sline Industrial Painters, Inc. (1982)

Background On December 28, 1979, Alcide Guidry, a 53-year-old industrial painter, arrived at work as usual at 7:30 a.m. for Sline Industrial Painters. Assigned with a colleague to paint large...

Throwback Thursday: Guidry v. Sline Industrial Painters, Inc. (1982) Throwback Thursday: Guidry v. Sline Industrial Painters, Inc. (1982)
Mar 4, 2025

California Supreme Court Preserves Maritime Claims for Workers Excluded from LHWCA

In an important decision for maritime law and workers’ rights, the California Supreme Court has ruled that workers excluded from the federal Longshore and Harbor Workers’ Compensation Act (LHWCA) may...

California Supreme Court Preserves Maritime Claims for Workers Excluded from LHWCA California Supreme Court Preserves Maritime Claims for Workers Excluded from LHWCA
Mar 3, 2025

PA Court Rules on COVID-19 “E-Time” Payments in Workers’ Comp Case

In a recent Pennsylvania workers’ compensation case, the state’s Commonwealth Court ruled that pandemic-related “excused time” payments, such as Philadelphia’s “E-Time” program, do not constitute “payments in lieu of compensation”...

PA Court Rules on COVID-19 “E-Time” Payments in Workers’ Comp Case PA Court Rules on COVID-19 “E-Time” Payments in Workers’ Comp Case
Feb 27, 2025

Throwback Thursday: Waters v. William J. Taylor Co. (1916) – The Humanitarian Rescue Doctrine

Background In 1916, the New York Court of Appeals issued a groundbreaking decision that would fundamentally shape how workers’ compensation law treats rescue attempts. The case, Waters v. William J....

Throwback Thursday: Waters v. William J. Taylor Co. (1916) – The Humanitarian Rescue Doctrine Throwback Thursday: Waters v. William J. Taylor Co. (1916) – The Humanitarian Rescue Doctrine
Feb 26, 2025

Florida Court Nixes Worker’s Comp Award for Spouse’s Household Chores

Yesterday, in Girardin v. An Fort Myers Imps., LLC (2025 Fla. App. LEXIS 1292, Feb. 19, 2025), Florida’s First District Court of Appeal struck down an award for attendant care...

Florida Court Nixes Worker’s Comp Award for Spouse’s Household Chores Florida Court Nixes Worker’s Comp Award for Spouse’s Household Chores
Feb 20, 2025

Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job

Background In 1928, the Minnesota Supreme Court issued a decision that would help establish important principles about when off-premises lunch injuries fall within the scope of workers’ compensation coverage. The...

Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job
Feb 19, 2025

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence

In a decision that reinforces the potential consequences of misrepresenting one’s physical condition, a New York appellate court has upheld the permanent disqualification from wage replacement benefits of a workers’...

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence
Feb 18, 2025

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits

In an unpublished decision, a Kansas appellate court has struck down an employer’s attempt to deny workers’ compensation benefits to an employee who refused a drug test 18 days after...

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits
Feb 14, 2025

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim

In Matter of Tudor v. Whitehall Cent. Sch. Dist., 2025 N.Y. App. Div. LEXIS 827 (3d Dept., Feb. 13, 2025), the New York Appellate Division, Third Department, affirmed the state...

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim
Feb 13, 2025

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)

Background On May 21, 1946, Kelly fell and injured his left knee in an accident which arose out of and in the course of his employment with the employer. He...

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949) Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)
Feb 10, 2025

Florida Workers’ Comp Lien Includes Post-Settlement Benefits

A Florida appellate court has ruled that a workers’ compensation carrier’s statutory lien rights extend to all benefits paid through the date of equitable distribution, not merely those paid through...

Florida Workers’ Comp Lien Includes Post-Settlement Benefits Florida Workers’ Comp Lien Includes Post-Settlement Benefits
Feb 7, 2025

SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute

In Russell v. Wal-Mart Stores, Inc., 2025 S.C. LEXIS 13 (Jan. 29, 2025), the South Carolina Supreme Court reversed a Workers’ Compensation Commission ruling that denied an injured worker additional...

SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute

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