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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
Jan 6, 2025

Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence

In Spisa-Kline v. Mary Lanning Memorial Hospital, 2024 Neb. App. LEXIS 750 (Dec. 31, 2024), the Nebraska Court of Appeals affirmed summary judgment for the employer in a workers’ compensation...

Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence
Dec 31, 2024

Oregon Jaywalker Might Be Awarded Benefits

Appeals Court Examines Going and Coming Rule The Oregon Court of Appeals has reversed and remanded a Workers’ Compensation Board decision that had denied benefits to a worker injured while...

Oregon Jaywalker Might Be Awarded Benefits Oregon Jaywalker Might Be Awarded Benefits
Dec 30, 2024

NC Court of Appeals Reverses $28.9 Million Tort Judgment

Insurer Had No Duty to Defend Intentional Tort Claim Against Co-Employee In Ortez v. Penn Nat’l Sec. Ins. Co., 2024 N.C. App. LEXIS 1017 (Dec. 17, 2024), the North Carolina...

NC Court of Appeals Reverses $28.9 Million Tort Judgment NC Court of Appeals Reverses $28.9 Million Tort Judgment

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Feb 22, 2022

Florida Teacher’s Fall After His Leg Went to Sleep is Not Compensable

A Florida appellate court affirmed a state JCC’s denial of a claim filed by a teacher who sustained a broken left femur when he lost his balance and fell after...

Florida Teacher’s Fall After His Leg Went to Sleep is Not Compensable Florida Teacher’s Fall After His Leg Went to Sleep is Not Compensable
Feb 21, 2022

NV Cannabis Dispensary’s Employee Might Recover for Injuries Sustained in Altercation with Customer

Finding that a Nevada appeals officer had focused too narrowly on an employee’s work-related duties and had not considered the totality of the circumstances in determining if the employee’s injury...

NV Cannabis Dispensary’s Employee Might Recover for Injuries Sustained in Altercation with Customer NV Cannabis Dispensary’s Employee Might Recover for Injuries Sustained in Altercation with Customer
Feb 17, 2022

Civil Action Related to COVID-19 Death of Texas Employee Barred by Exclusivity

A federal district court, sitting in Texas and construing Texas law, granted a defendant-employer’s motion for summary judgment in a civil action filed against it by the family of a...

Civil Action Related to COVID-19 Death of Texas Employee Barred by Exclusivity Civil Action Related to COVID-19 Death of Texas Employee Barred by Exclusivity
Feb 15, 2022

Light-Duty NY Worker Gets No Reduced Earnings Benefits Following COVID-19 Cutbacks

Where, after his work-related injury, a New York employee returned to light work for a different employer and then was laid off due to cutbacks related to the COVID-19 pandemic,...

Light-Duty NY Worker Gets No Reduced Earnings Benefits Following COVID-19 Cutbacks Light-Duty NY Worker Gets No Reduced Earnings Benefits Following COVID-19 Cutbacks
Feb 14, 2022

Ex Parte Letter to Treating Physician Sinks NY Truck Driver’s Occupational Disease Claim

Stressing that it is for the New York Workers’ Compensation Board to weigh the evidence—including the medical evidence—and that the Board’s findings will be upheld if supported by substantial evidence,...

Ex Parte Letter to Treating Physician Sinks NY Truck Driver’s Occupational Disease Claim Ex Parte Letter to Treating Physician Sinks NY Truck Driver’s Occupational Disease Claim
Feb 11, 2022

Mass Shooting Victim’s NY Civil Action May Move Forward Against Employer

In a case arising out of a tragic and bizarre 2017 multiple-shooting incident at a New York hospital, a state appellate court reversed a decision of the Empire State’s Workers’...

Mass Shooting Victim’s NY Civil Action May Move Forward Against Employer Mass Shooting Victim’s NY Civil Action May Move Forward Against Employer
Feb 10, 2022

Florida JCC May Not Strike Authorized Physician Because of Fee Dispute

Yesterday, a Florida appellate court held the state’s Workers’ Compensation Code (Code) does not authorize a Judge of Compensation Claims (JCC) to strike a physician authorized by the Employer/Carrier (E/C)...

Florida JCC May Not Strike Authorized Physician Because of Fee Dispute Florida JCC May Not Strike Authorized Physician Because of Fee Dispute
Feb 8, 2022

Bus Camera Video Sinks NY City Driver’s Back Injury Claim

Substantial evidence supported the New York Workers’ Compensation Board’s determination that a claimant, a bus driver, had not sustained an injury arising out of and in the course of his...

Bus Camera Video Sinks NY City Driver’s Back Injury Claim Bus Camera Video Sinks NY City Driver’s Back Injury Claim
Feb 7, 2022

Battle Continues in Kansas Over Use of 6th Edition of AMA Guides

In the continuing battle in Kansas over the use of the Sixth Edition of the American Medical Association (AMA) Guides to the Evaluation of Permanent Impairment, a divided Court of...

Battle Continues in Kansas Over Use of 6th Edition of AMA Guides Battle Continues in Kansas Over Use of 6th Edition of AMA Guides
Feb 2, 2022

Judicial Estoppel Bars NY Defendants’ Exclusive Remedy Defense

In a divided decision, a New York appellate court held that where a Manpower, Inc. temporary worker was assigned to conduct inventory control at a pharmaceutical plant operated by two...

Judicial Estoppel Bars NY Defendants’ Exclusive Remedy Defense Judicial Estoppel Bars NY Defendants’ Exclusive Remedy Defense
Feb 1, 2022

PA Employer’s Right to Subrogation is “Absolute”

Acknowledging that a trial court in a declaratory action had fixed the injured employee’s total damages in his third-party tort claim at almost $2 million, designating $1,500,000 of that total...

PA Employer’s Right to Subrogation is “Absolute” PA Employer’s Right to Subrogation is “Absolute”
Jan 31, 2022

IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit

The exclusive remedy provisions of the Illinois Workers' Compensation Act (Act)—820 ILCS 305/5(a), 11— do not extend to a general contractor who paid workers’ compensation insurance premiums and benefits for...

IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit

New Comments

  • 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...
  • kathlyn gorman: It should have been noted in your discussion that this is an unpublished opinion of the North Carolina Court of Appeals. Thus, it does not constitute controlling legal authority.
  • Thomas A. Robinson: You're correct. Ordinarily, I can depend upon Alabama to provide me with at least one case for "the List." I'll bet 2022 will unearth something bizarre from the Great State of Alabama. Take care.