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Jun 5, 2025

Throwback Thursday: Boyd v. Young (1951)

When Cancer Meets Causation: Wrestling with Medical Mystery in 1951 In workers’ compensation law, few challenges prove more vexing than establishing causation when the medical community itself admits ignorance about...

Throwback Thursday: Boyd v. Young (1951) Throwback Thursday: Boyd v. Young (1951)
Jun 3, 2025

Iowa High Court Says Gross Negligence/Fraud Claims Can Go Forward Against Tyson Executives

In an important decision construing the Iowa doctrine that allows gross negligence and fraudulent misrepresentation tort claims against co-employees, the Iowa Supreme Court has revived claims against Tyson Foods executives...

Iowa High Court Says Gross Negligence/Fraud Claims Can Go Forward Against Tyson Executives Iowa High Court Says Gross Negligence/Fraud Claims Can Go Forward Against Tyson Executives
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

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Oct 13, 2022

Opinion Mondays: As to AMA Guides, is There an Alternative to Protz?

In a decision that may have slipped beneath the radar of insurers, administrators, and attorneys whose work is not directly impacted by the Longshore and Harbor Workers’ Compensation Act [33 U.S.C.S §§ 901, et seq.] (“the Act” or “the Longshore Act”), and yet which, as I argue below...

Opinion Mondays: As to AMA Guides, is There an Alternative to Protz? Opinion Mondays: As to AMA Guides, is There an Alternative to Protz?
Oct 13, 2022

Opinion Mondays: The AMA is on Another Collision Course With Protz

The first session at tomorrow afternoon's (August 18, 2020) virtual conference, sponsored by Workers' Compensation Institute, has really piqued my interest. Entitled, "THE NEW AMA Guides®" (hereinafter "the Guides"), it begs the question: "When will the 7th Edition of the Guides be released?"....

Opinion Mondays: The AMA is on Another Collision Course With Protz Opinion Mondays: The AMA is on Another Collision Course With Protz
Oct 11, 2022

No Violation of N.Y. Workers’ Comp. Law § 114-a Where Testimony Inconsistencies Explained by Head Injury

A New York appellate court affirmed a finding of a state WCLJ, affirmed by the New York Workers’ Compensation Board, that a claimant had not made misrepresentations regarding his prior...

No Violation of N.Y. Workers’ Comp. Law § 114-a Where Testimony Inconsistencies Explained by Head Injury No Violation of N.Y. Workers’ Comp. Law § 114-a Where Testimony Inconsistencies Explained by Head Injury
Oct 4, 2022

NY Claimant Entitled to Marked Permanent Disability Award Instead of SLU Award

Construing the N.Y. Workers’ Compensation Guidelines for Determining Impairment, a state appellate court affirmed a decision of the Workers’ Compensation Board that held an injured employee’s foot injury was not...

NY Claimant Entitled to Marked Permanent Disability Award Instead of SLU Award NY Claimant Entitled to Marked Permanent Disability Award Instead of SLU Award
Oct 3, 2022

Failure to Disclose Earnings From Home-Based Business is Violation of NY Fraud Statute

Where a New York workers’ compensation claimant testified that he had not worked after a specific date and also represented to a carrier’s medical consultant that he had stopped working...

Failure to Disclose Earnings From Home-Based Business is Violation of NY Fraud Statute Failure to Disclose Earnings From Home-Based Business is Violation of NY Fraud Statute
Sep 29, 2022

Injuries Sustained by MS Worker in Fight Over Country Music Not Compensable

In a case with a bizarre fact pattern, a Mississippi appellate court affirmed the denial of workers’ compensation benefits to a worker who sustained injuries in a workplace altercation [Hollis...

Injuries Sustained by MS Worker in Fight Over Country Music Not Compensable Injuries Sustained by MS Worker in Fight Over Country Music Not Compensable
Sep 27, 2022

NC Court Affirms Death Benefits Award Under State’s “Found Dead” Presumption

The Court of Appeals of North Carolina, construing the state’s version of the “found dead” rule, affirmed a decision by the state’s Industrial Commission that awarded death benefits to the...

NC Court Affirms Death Benefits Award Under State’s “Found Dead” Presumption NC Court Affirms Death Benefits Award Under State’s “Found Dead” Presumption
Sep 21, 2022

Illinois Employee’s Termination Not Retaliatory Where it Occurred Six Weeks Prior to His Filing Comp Claim

Where an Illinois employee failed to indicate to his employer that his absence from work was due to an alleged work-related injury and he filed his workers’ compensation claim six...

Illinois Employee’s Termination Not Retaliatory Where it Occurred Six Weeks Prior to His Filing Comp Claim Illinois Employee’s Termination Not Retaliatory Where it Occurred Six Weeks Prior to His Filing Comp Claim
Sep 19, 2022

NC Employer May Not Use Truck Driver’s “Misconduct” in Causing Accident as Excuse for Denying TTD Benefits

Where a North Carolina truck driver was terminated from employment because the employer determined that the driver had been at fault in causing an accident that resulted in his injuries,...

NC Employer May Not Use Truck Driver’s “Misconduct” in Causing Accident as Excuse for Denying TTD Benefits NC Employer May Not Use Truck Driver’s “Misconduct” in Causing Accident as Excuse for Denying TTD Benefits
Sep 12, 2022

Virginia Worker’s Post-Injury Decision to be “Off-Work” Due to COVID-19 Sinks TTD Claim

A Virginia part-time employee, who was able to work without restrictions for three months, following a work-related injury, and who then was “taken off work” by his cardiologist because of...

Virginia Worker’s Post-Injury Decision to be “Off-Work” Due to COVID-19 Sinks TTD Claim Virginia Worker’s Post-Injury Decision to be “Off-Work” Due to COVID-19 Sinks TTD Claim
Aug 31, 2022

New Mexico Court Discusses State’s “Peculiar” Going and Coming Rule

In an unusual case that turned on the “peculiar” wording of New Mexico’s statutory going and coming rule, the Court of Appeals of New Mexico affirmed a decision by a...

New Mexico Court Discusses State’s “Peculiar” Going and Coming Rule New Mexico Court Discusses State’s “Peculiar” Going and Coming Rule
Aug 30, 2022

Employee Recovers for Idiopathic Fall Under Louisiana’s Positional Risk Doctrine

A Louisiana appellate court recently affirmed a determination by a WCJ that a pharmacy technician’s injuries resulting from a fall at her computer station after she had suffered a one-time...

Employee Recovers for Idiopathic Fall Under Louisiana’s Positional Risk Doctrine Employee Recovers for Idiopathic Fall Under Louisiana’s Positional Risk Doctrine

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...