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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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Jan 4, 2022

Florida Court Agrees Firefighter Not Entitled to Reimbursement for Back Surgery

A Florida appellate court has affirmed a decision of a Judge of Compensation Claims (JCC) holding that an injured firefighter was not entitled to reimbursement for additional surgical expenses related...

Florida Court Agrees Firefighter Not Entitled to Reimbursement for Back Surgery Florida Court Agrees Firefighter Not Entitled to Reimbursement for Back Surgery
Jan 3, 2022

NY Board Abused Discretion in Failing to Allow Carrier’s Review Application

In a claim tangental to a highly-publicized 2019 indictment for alleged workers’ compensation fraud, a New York appellate court held that the state’s Workers’ Compensation Board abused its discretion when...

NY Board Abused Discretion in Failing to Allow Carrier’s Review Application NY Board Abused Discretion in Failing to Allow Carrier’s Review Application
Dec 29, 2021

NY Firefighter Successfully Proved PTSD Claim Based Upon Multiple Gruesome Incidents

Noting that a medical opinion need not be expressed with absolute medical certainty as long as it signified a probability of the underlying cause that was supported by a rational...

NY Firefighter Successfully Proved PTSD Claim Based Upon Multiple Gruesome Incidents NY Firefighter Successfully Proved PTSD Claim Based Upon Multiple Gruesome Incidents
Dec 27, 2021

PA Supreme Court “Corrects” Long-Standing Rule Regarding Award of Attorney’s Fees Against Employer Who Reasonably Contests Issues

In a decision that is turning heads in the Keystone State, the Supreme Court of Pennsylvania, stressing the importance differences between two words—“shall” and “may”—reversed a decision by the state’s...

PA Supreme Court “Corrects” Long-Standing Rule Regarding Award of Attorney’s Fees Against Employer Who Reasonably Contests Issues PA Supreme Court “Corrects” Long-Standing Rule Regarding Award of Attorney’s Fees Against Employer Who Reasonably Contests Issues
Dec 24, 2021

California Comp Act Does Not Bar COVID-19 Wrongful Death Claim

In an important decision that is certain to garner attention well beyond California’s borders, a California appellate court denied a petition for writ of mandate filed by an employer who...

California Comp Act Does Not Bar COVID-19 Wrongful Death Claim California Comp Act Does Not Bar COVID-19 Wrongful Death Claim
Dec 21, 2021

IL Supreme Court Sidesteps Important Issue on Technical Grounds

Dodging an issue that had spawned multiple amicus curiae briefs regarding an interesting (and important) question—whether an employee’s representation in a workers’ compensation settlement agreement that he had only suffered...

IL Supreme Court Sidesteps Important Issue on Technical Grounds IL Supreme Court Sidesteps Important Issue on Technical Grounds
Dec 16, 2021

Iowa Court Affirms Denial of Death Benefits in Suicide Case

An Iowa appellate court affirmed a district court’s decision affirming the denial of death benefits to a widow whose husband committed suicide mere hours after he had been terminated from...

Iowa Court Affirms Denial of Death Benefits in Suicide Case Iowa Court Affirms Denial of Death Benefits in Suicide Case
Dec 14, 2021

Federal Court Dismisses Racially-Based IIED Suit Filed Against Co-Employee

A federal district court, construing Missouri law, dismissed a civil action filed by one employee against another alleging negligent infliction of emotional distress (“NIED”) and intentional infliction of emotional distress...

Federal Court Dismisses Racially-Based IIED Suit Filed Against Co-Employee Federal Court Dismisses Racially-Based IIED Suit Filed Against Co-Employee
Dec 13, 2021

Arkansas Court Affirms Revocation of Pharmacy License in Pain Cream Cases

A divided division of the Arkansas Court of Appeals has affirmed a decision by the state’s Board of Pharmacy that revoked the permit and license of a pharmacy and an...

Arkansas Court Affirms Revocation of Pharmacy License in Pain Cream Cases Arkansas Court Affirms Revocation of Pharmacy License in Pain Cream Cases
Dec 10, 2021

SC Appellate Court Chides Commission for Summarily Dismissing Appeal

In a stinging decision, the Court of Appeals of South Carolina ruled that the state’s Workers’ Compensation Commission had abused its discretion in summarily dismissing the appeal by an insurance...

SC Appellate Court Chides Commission for Summarily Dismissing Appeal SC Appellate Court Chides Commission for Summarily Dismissing Appeal
Dec 9, 2021

For Limitations Purposes, a NC Death Claim Cannot Piggy-Back Onto Deceased Employee’s Original Filing

A divided panel of the North Carolina Court of Appeals recently affirmed a decision by the state’s Industrial Commission that had found it lacked jurisdiction to hear a widow’s death...

For Limitations Purposes, a NC Death Claim Cannot Piggy-Back Onto Deceased Employee’s Original Filing For Limitations Purposes, a NC Death Claim Cannot Piggy-Back Onto Deceased Employee’s Original Filing
Dec 7, 2021

PA Police Officer Awarded Benefits for PTSD After “No-Holds-Barred” Meeting

In an unreported opinion, the Commonwealth Court of Pennsylvania affirmed an award of total disability benefits to former police officer for a psychological injury in the form of PTDS, depression,...

PA Police Officer Awarded Benefits for PTSD After “No-Holds-Barred” Meeting PA Police Officer Awarded Benefits for PTSD After “No-Holds-Barred” Meeting

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.