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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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Feb 6, 2025

Throwback Thursday: Bailey v. American General Ins. Co. (1955)

The Case and Its Context The 1955 Texas Supreme Court decision in Bailey v. American General Insurance Co., 154 Tex. 430, 279 S.W.2d 315 (1955), represents a landmark in the...

Throwback Thursday: Bailey v. American General Ins. Co. (1955) Throwback Thursday: Bailey v. American General Ins. Co. (1955)
Feb 4, 2025

Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable

In a case of first impression, an Illinois appellate court has held that work-related pain alone—without accompanying structural change or worsening—can constitute a compensable aggravation of a pre-existing asymptomatic condition...

Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable
Feb 3, 2025

GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns

A Georgia appellate court recently reversed a state Workers’ Compensation Board decision that denied temporary total disability (TTD) benefits to an employee who refused light-duty work due to COVID-19 health...

GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns
Jan 30, 2025

Throwback Thursday: Whetro v. Awkerman (1970)

When Mother Nature Met Workers’ Compensation On Palm Sunday 1965, a devastating series of tornadoes tore through southern Michigan. Among the victims were two workers: Carl Whetro, injured when the...

Throwback Thursday: Whetro v. Awkerman (1970) Throwback Thursday: Whetro v. Awkerman (1970)
Jan 28, 2025

“Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer

An Ohio employer cannot be held liable under the doctrine of respondeat superior for an employee’s negligent driving during a commute to work, even where the employee might reasonably be...

“Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer “Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer
Jan 27, 2025

IL Supreme Court: Widow Can Sue in Tort Although Husband’s Exposure to Toxins Occurred Before 2019 Legislative Change

An Illinois widow may pursue a civil action against her deceased husband’s employer for his asbestos-related death, even though his exposure occurred decades before a 2019 amendment to the state’s...

IL Supreme Court: Widow Can Sue in Tort Although Husband’s Exposure to Toxins Occurred Before 2019 Legislative Change IL Supreme Court: Widow Can Sue in Tort Although Husband’s Exposure to Toxins Occurred Before 2019 Legislative Change
Jan 23, 2025

Throwback Thursday: Booker v. Duke Medical Center (1979)

Background In the late 1960s and early 1970s, Robert Booker worked as a laboratory technician at Duke Medical Center in Durham, North Carolina, performing routine chemical tests on blood specimens....

Throwback Thursday: Booker v. Duke Medical Center (1979) Throwback Thursday: Booker v. Duke Medical Center (1979)
Jan 20, 2025

No PTSD Benefits for NY City Bus Driver

Passenger’s Attack Just Part of Driver’s “Normal Work Environment” In Matter of Waddy v. Manhattan & Bronx Surface Tr. Auth., 2025 N.Y. App. Div. LEXIS 244 (3rd Dept. Jan. 16,...

No PTSD Benefits for NY City Bus Driver No PTSD Benefits for NY City Bus Driver
Jan 14, 2025

MN: Driver’s Co-Employee Immunity Doesn’t Shield Vehicle Owners From Liability

Yesterday, reversing a trial court’s decision granting defendant vehicle owners’ motion for summary judgment, in Niebuhr v. Sieberg, 2025 Minn. App. LEXIS 4 (Jan. 13, 2025), the Minnesota Court of...

MN: Driver’s Co-Employee Immunity Doesn’t Shield Vehicle Owners From Liability MN: Driver’s Co-Employee Immunity Doesn’t Shield Vehicle Owners From Liability
Jan 13, 2025

VT High Court Upholds Administrative Rule on Concurrent Employment Wage Calculations

In a unanimous decision, Hill v. Agri-Mark, Inc., 2025 VT 3, 2025 Vt. LEXIS 2 (Jan. 10, 2025), the Supreme Court of Vermont affirmed the state Department of Labor’s authority...

VT High Court Upholds Administrative Rule on Concurrent Employment Wage Calculations VT High Court Upholds Administrative Rule on Concurrent Employment Wage Calculations
Jan 7, 2025

What Should the Tort Jury Know About Comp Benefits Already Received?

NC Court Should Not Disclose Power of Court to Reduce Employer’s Comp Lien The North Carolina Court of Appeals recently held that despite the statutory requirement that a trial judge...

What Should the Tort Jury Know About Comp Benefits Already Received? What Should the Tort Jury Know About Comp Benefits Already Received?
Jan 6, 2025

Iowa Court Affirms Denial of Benefits re: COVID-19 Claim

In Collins v. Des Moines Area Regional Transit Authority (DART), 2024 Iowa App. LEXIS 918 (Dec. 18, 2024), the Iowa Court of Appeals affirmed denial of workers’ compensation benefits to...

Iowa Court Affirms Denial of Benefits re: COVID-19 Claim Iowa Court Affirms Denial of Benefits re: COVID-19 Claim

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