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May 29, 2025

Throwback Thursday: Prows v. Industrial Commission of Utah (1980)

A Horseplay Case That Shaped Utah’s Workers’ Compensation Doctrine In Prows v. Industrial Commission of Utah, 610 P.2d 1362 (Utah 1980), the Supreme Court of Utah was presented with a...

Throwback Thursday: Prows v. Industrial Commission of Utah (1980) Throwback Thursday: Prows v. Industrial Commission of Utah (1980)
May 27, 2025

When the Boss Wears Two Hats

Exclusivity Does Not Shield Corporate Officers/Property Owners From Liability as Landlords In Nelson v. Smith, 2025 N.C. App. LEXIS 306 (May 21, 2025), the North Carolina Court of Appeals reversed...

When the Boss Wears Two Hats When the Boss Wears Two Hats
May 22, 2025

Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975)

Tools, Timing, and Termination In Nails v. Market Tire Co., 29 Md. App. 154, 347 A.2d 564 (Md. Ct. Spec. App. 1975), the Maryland Court of Special Appeals addressed a...

Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975) Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975)
May 20, 2025

Food Delivery Driver’s Tort Claim Against Pizzeria Barred by KY’s Up-the-Ladder Immunity Rule

In a fresh decision that further solidifies Kentucky’s robust up-the-ladder immunity doctrine, a federal district court has dismissed a negligence action filed by a food supplier’s delivery driver against a...

Food Delivery Driver’s Tort Claim Against Pizzeria Barred by KY’s Up-the-Ladder Immunity Rule Food Delivery Driver’s Tort Claim Against Pizzeria Barred by KY’s Up-the-Ladder Immunity Rule

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May 1, 2025

Throwback Thursday: Martin v. Industrial Accident Commission (1956)

Refusal of Life-Saving Treatment Within Workers’ Compensation Context In Martin v. Industrial Accident Commission, 147 Cal. App. 2d 137, 304 P.2d 828 (Cal. Ct. App. 1956), the California Court of...

Throwback Thursday: Martin v. Industrial Accident Commission (1956) Throwback Thursday: Martin v. Industrial Accident Commission (1956)
Apr 30, 2025

Arkansas Court Enforces Strict Dependency Hierarchy Despite Estrangement

In a decision underscoring the rigid statutory structure governing death benefits in workers’ compensation law, the Arkansas Court of Appeals recently affirmed the denial of benefits to the parents of...

Arkansas Court Enforces Strict Dependency Hierarchy Despite Estrangement Arkansas Court Enforces Strict Dependency Hierarchy Despite Estrangement
Apr 29, 2025

Georgia Court Blocks Assigned Negligence Claim Over Lapsed Workers’ Compensation Coverage

In Diaz Arriola v. Coleman, 2025 Ga. App. LEXIS 161 (Apr. 24, 2025), the Georgia Court of Appeals affirmed the dismissal of an injured employee’s assigned negligence and breach of...

Georgia Court Blocks Assigned Negligence Claim Over Lapsed Workers’ Compensation Coverage Georgia Court Blocks Assigned Negligence Claim Over Lapsed Workers’ Compensation Coverage
Apr 28, 2025

Hawaii Supreme Court Clarifies Employee Status in Workers’ Compensation Context

The Hawai’i Supreme Court recently held that a tenant who performed maintenance work on rental property, in exchange for reduced rent and occasional payment, was an employee—not a volunteer—and accordingly...

Hawaii Supreme Court Clarifies Employee Status in Workers’ Compensation Context Hawaii Supreme Court Clarifies Employee Status in Workers’ Compensation Context
Apr 24, 2025

Throwback Thursday: Lee v. Minneapolis Street Railway Co. (1950)

The Rise of the Odd-Lot Doctrine In the world of workers’ compensation, some of the most influential doctrines arise not from statutory overhaul or regulatory edict, but from judicial insight...

Throwback Thursday: Lee v. Minneapolis Street Railway Co. (1950) Throwback Thursday: Lee v. Minneapolis Street Railway Co. (1950)
Apr 22, 2025

SD Supreme Court Weighs Conflicting Medical Evidence

Reverses Factual Findings Where Evidence Was in Deposition Form In a split decision, the South Dakota Supreme Court reversed—in relevant part—a Department of Labor determination that had ruled a claimant’s...

SD Supreme Court Weighs Conflicting Medical Evidence SD Supreme Court Weighs Conflicting Medical Evidence
Apr 21, 2025

MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases

In a thoughtful and clarifying opinion, the Minnesota Supreme Court has reaffirmed the case-specific nature of the statutory retirement presumption applicable to permanent total disability (PTD) claims under Minn. Stat....

MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases
Apr 17, 2025

Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951)

Introduction In 1951, the U.S. Supreme Court handed down its decision in O’Leary v. Brown-Pacific-Maxon, Inc., 340 U.S. 504, 71 S.Ct. 470, 95 L.Ed.483 (1951). The case involved a claim...

Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951) Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951)
Apr 15, 2025

Arkansas Court Denies Benefits to Good Samaritan Band Director

In a ruling that reaffirms Arkansas’ strict interpretation of its “employment services” requirement, the state’s Court of Appeals recently affirmed a Workers’ Compensation Commission decision denying benefits to the family...

Arkansas Court Denies Benefits to Good Samaritan Band Director Arkansas Court Denies Benefits to Good Samaritan Band Director
Apr 14, 2025

Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack

In a decision that further defines the barriers to pursuing civil remedies in workplace injury cases within the Louisiana, a state appellant court recently affirmed summary a trial court judgment...

Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack
Apr 10, 2025

Throwback Thursday: Hawk v. Jim Hawk Chevrolet-Buick, Inc., 282 N.W.2d 84 (Iowa 1979)

Background On September 28, 1973, at approximately 2:30 a.m., James Hawk II, the president, sole stockholder, and chief operating officer of Jim Hawk Chevrolet-Buick, Inc., died when his private airplane...

Throwback Thursday: Hawk v. Jim Hawk Chevrolet-Buick, Inc., 282 N.W.2d 84 (Iowa 1979) Throwback Thursday: Hawk v. Jim Hawk Chevrolet-Buick, Inc., 282 N.W.2d 84 (Iowa 1979)
Apr 8, 2025

NC Court Rejects Tort Claim for Workplace Fatality

In a decision that underscores the high bar for pursuing civil remedies alongside a workers’ compensation claim, the North Carolina Court of Appeals recently affirmed summary judgment against the estate...

NC Court Rejects Tort Claim for Workplace Fatality NC Court Rejects Tort Claim for Workplace Fatality

New Comments

  • 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
  • Thomas A. Robinson: Good point, although the interesting thing about the case--at least to me--is that it discusses the important "injury by accident" issue. That issue, present in at least a plurality of state acts, is largely ignored by Commissions, Boards, and Courts these days. Here, also, the case was so fact-specific that even it had been issued as published, it would be factually distinguishable from many othe...