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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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Aug 29, 2022

Ohio Court Stresses Not All Employer Parking Lot Injuries are Compensable

In a recent decision that outlines and clarifies several important issues related to injuries in an employer-owned or controlled parking lot, an Ohio appellate court reversed a trial court’s determination...

Ohio Court Stresses Not All Employer Parking Lot Injuries are Compensable Ohio Court Stresses Not All Employer Parking Lot Injuries are Compensable
Aug 10, 2022

Signed Mediation Agreement Binds Employer/Carrier to $1 Million Payment in Spite of Worker’s Death Seven Days After Mediation

Observing that after a 2007 amendment to S.C Code § 42-9-390, an agreement settling a workers’ compensation dispute no longer had to be approved by the Commission if both parties...

Signed Mediation Agreement Binds Employer/Carrier to $1 Million Payment in Spite of Worker’s Death Seven Days After Mediation Signed Mediation Agreement Binds Employer/Carrier to $1 Million Payment in Spite of Worker’s Death Seven Days After Mediation
Aug 9, 2022

Ohio Social Worker’s Slip and Fall Injuries in Icy Restaurant Parking Lot Did Not Arise from His Employment

An Ohio appellate court disagreed with the trial court’s conclusion that a social worker was a fixed situs employee whose injuries sustained when he slipped and fell in a restaurant...

Ohio Social Worker’s Slip and Fall Injuries in Icy Restaurant Parking Lot Did Not Arise from His Employment Ohio Social Worker’s Slip and Fall Injuries in Icy Restaurant Parking Lot Did Not Arise from His Employment
Aug 8, 2022

PA Court: Employer Need Not Pay Estimated Cost of Modifying Paraplegic’s Current Home Toward Purchase of New Home

Where a Pennsylvania construction worker, who had been rendered a paraplegic in a compensable workplace injury, obtained a bona fide estimate indicating it would cost more than $119,000 to to...

PA Court: Employer Need Not Pay Estimated Cost of Modifying Paraplegic’s Current Home Toward Purchase of New Home PA Court: Employer Need Not Pay Estimated Cost of Modifying Paraplegic’s Current Home Toward Purchase of New Home
Jul 21, 2022

Louisiana Plaintiff’s Civil Action Against Company Barred by Workers’ Comp Settlement

A Louisiana appellate court held a plaintiff could not maintain a tort action against a defendant where the plaintiff and the defendant had settled a workers’ compensation action that involved...

Louisiana Plaintiff’s Civil Action Against Company Barred by Workers’ Comp Settlement Louisiana Plaintiff’s Civil Action Against Company Barred by Workers’ Comp Settlement
Jul 20, 2022

No Recovery for FL Mother Whose 16-Year-Old Son Died on First Day of Work

A Florida appellate court affirmed the denial of death benefits to a mother whose 16-year-old son was killed in a tragic drowning accident on the first day of his part-time...

No Recovery for FL Mother Whose 16-Year-Old Son Died on First Day of Work No Recovery for FL Mother Whose 16-Year-Old Son Died on First Day of Work
Jul 18, 2022

Kansas Court Says Dual Capacity Doctrine Not Applicable Where Employer Manufactured Machine Causing Employee’s Injury

Observing that in Kansas, like a number of other states, an employer may be liable in tort as a “third-party tortfeasor” if the employer has obligations to the employee independent...

Kansas Court Says Dual Capacity Doctrine Not Applicable Where Employer Manufactured Machine Causing Employee’s Injury Kansas Court Says Dual Capacity Doctrine Not Applicable Where Employer Manufactured Machine Causing Employee’s Injury
Jun 28, 2022

Delaware Employer Need Not Pay for Claimant’s Opioids More than 9 Years After Accident

The Delaware Supreme Court affirmed a decision of the Superior Court that in turn had affirmed a decision by the state’s Industrial Accident Board (“IAB”) granting an employer’s petition for...

Delaware Employer Need Not Pay for Claimant’s Opioids More than 9 Years After Accident Delaware Employer Need Not Pay for Claimant’s Opioids More than 9 Years After Accident
Jun 27, 2022

NY Court: Not Every Omission of Prior Injury Constitutes Misrepresentation under § 114-a

A New York appellate court affirmed a determination by the state’s Workers’ Compensation Board that had rescinded that part of a WCLJ’s decision finding that the claimant violated N.Y. Workers’...

NY Court: Not Every Omission of Prior Injury Constitutes Misrepresentation under § 114-a NY Court: Not Every Omission of Prior Injury Constitutes Misrepresentation under § 114-a
Jun 21, 2022

Ohio Court Affirms Finding that Furnace Worker’s COVID-19 Was Not Compensable

Finding that a furnace worker had failed to establish the necessary third prong in the definition of occupational diseases—that his employment created a risk of contracting the disease (here, COVID-19)...

Ohio Court Affirms Finding that Furnace Worker’s COVID-19 Was Not Compensable Ohio Court Affirms Finding that Furnace Worker’s COVID-19 Was Not Compensable
Jun 20, 2022

KY Supreme Court: Noted Medical Authority’s AMA Guides Report Inadmissible

In a decision that may have attorneys in other states scurrying back to their respective statutes to check their states’ definitions of “physician,” the Supreme Court of Kentucky held that...

KY Supreme Court: Noted Medical Authority’s AMA Guides Report Inadmissible KY Supreme Court: Noted Medical Authority’s AMA Guides Report Inadmissible
Jun 3, 2022

Ohio Court Says Healthcare Benefits and Pension Contributions Not to be Used in Computing AWW

Quoting Larson’s Workers’ Compensation Law, an Ohio appellate court affirmed a decision by the state’s Industrial Commission that had refused to consider various fringe benefits in the form of health...

Ohio Court Says Healthcare Benefits and Pension Contributions Not to be Used in Computing AWW Ohio Court Says Healthcare Benefits and Pension Contributions Not to be Used in Computing AWW

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...