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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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Jun 2, 2022

Indefinite Medical Testimony Sinks NY Claimant’s Occupational Disease Claim

A New York appellate court held that where a physician testified that a claimant developed neck and shoulder pain “due to repetitive stress and forceful use of the upper extremities...

Indefinite Medical Testimony Sinks NY Claimant’s Occupational Disease Claim Indefinite Medical Testimony Sinks NY Claimant’s Occupational Disease Claim
May 31, 2022

Injured NY Freelance Technician Loses in Bid to Show Termination of Employment was Retaliatory

A New York appellate court affirmed a decision by the state’s Workers’ Compensation Board that a freelance per diem technician was not fired in retaliation for his filing of a...

Injured NY Freelance Technician Loses in Bid to Show Termination of Employment was Retaliatory Injured NY Freelance Technician Loses in Bid to Show Termination of Employment was Retaliatory
May 24, 2022

Failure to Disclose Prior Work-Related Injuries Proves Fatal for NY Worker’s Claim for Continued Benefits

A New York appellate court affirmed a decision by the state’s Workers’ Compensation Board that found an injured worker’s failure to disclose work-related injuries he sustained in 1998 and 2002,...

Failure to Disclose Prior Work-Related Injuries Proves Fatal for NY Worker’s Claim for Continued Benefits Failure to Disclose Prior Work-Related Injuries Proves Fatal for NY Worker’s Claim for Continued Benefits
May 23, 2022

120-Pound Weight Gain Might (or Might Not) Sink Idaho Worker’s Aggravation Claim

In a meticulous and well-reasoned opinion weighing and discussing multiple issues, the Supreme Court of Idaho held that the state’s Industrial Commission committed error when it ruled that the claimant’s...

120-Pound Weight Gain Might (or Might Not) Sink Idaho Worker’s Aggravation Claim 120-Pound Weight Gain Might (or Might Not) Sink Idaho Worker’s Aggravation Claim
May 17, 2022

Texas Court Stresses Comp Carrier is Entitled to Full “First Money” in Worker’s Third-Party Tort Settlement

Reiterating that aTexas workers’ compensation carrier is entitled to the “first money” an injured worker recovered in a third-party tort action—here, settlement of a medical malpractice claim—and stressing further that...

Texas Court Stresses Comp Carrier is Entitled to Full “First Money” in Worker’s Third-Party Tort Settlement Texas Court Stresses Comp Carrier is Entitled to Full “First Money” in Worker’s Third-Party Tort Settlement
May 9, 2022

RI Supreme Court Broadens “Parking Lot” Rule to Include Leased Properties

Under Rhode Island’s so-called Branco exception to the going and coming rule, an employee and/or the employee’s dependents may recover workers’ compensation benefits where the employee’s injury or death results...

RI Supreme Court Broadens “Parking Lot” Rule to Include Leased Properties RI Supreme Court Broadens “Parking Lot” Rule to Include Leased Properties
May 5, 2022

NC Court Reiterates that Full Commission, Not the Deputy Commissioner, is the Ultimate Factfinder

N.C. Gen. Stat. § 97-85(a), which empowers the North Carolina Industrial Commission to reconsider the evidence before the deputy commissioner, and to amend the deputy commissioner’s award “if good ground...

NC Court Reiterates that Full Commission, Not the Deputy Commissioner, is the Ultimate Factfinder NC Court Reiterates that Full Commission, Not the Deputy Commissioner, is the Ultimate Factfinder
May 3, 2022

To Rebut Idaho’s Cancer Presumption Favoring Firefighters, Employer Must Offer Evidence that Cancer was Not Caused by Employment

The Supreme Court of Idaho, construing Idaho Code § 72-438(14)(b), which generally provides firefighters with a rebuttable presumption that certain listed cancers have a causal connection with the employment, held...

To Rebut Idaho’s Cancer Presumption Favoring Firefighters, Employer Must Offer Evidence that Cancer was Not Caused by Employment To Rebut Idaho’s Cancer Presumption Favoring Firefighters, Employer Must Offer Evidence that Cancer was Not Caused by Employment
May 2, 2022

Lay Testimony Insufficient to Establish Causation for MS Claimant

Where a police officer had sustained three prior work-related injuries and sought to receive compensation for an alleged injury to his neck, the burden was on the employee to show...

Lay Testimony Insufficient to Establish Causation for MS Claimant Lay Testimony Insufficient to Establish Causation for MS Claimant
Apr 29, 2022

Florida Court Stresses There is No “Field Employee” Exception to Statutory Going and Coming Rule

A Florida appellate court held that a judge of compensation claims committed error when he determined that a construction worker who sustained severe injuries in a vehicular accident as he...

Florida Court Stresses There is No “Field Employee” Exception to Statutory Going and Coming Rule Florida Court Stresses There is No “Field Employee” Exception to Statutory Going and Coming Rule
Apr 26, 2022

NY Court Says Existence of Medical Restrictions Are Alone Insufficient to Establish Reduced Earnings Claim

A New York appellate court affirmed the state Board’s rescission of a WCLJ’s reduced earnings award where it found that while the workers’ compensation claimant did have medical restrictions following...

NY Court Says Existence of Medical Restrictions Are Alone Insufficient to Establish Reduced Earnings Claim NY Court Says Existence of Medical Restrictions Are Alone Insufficient to Establish Reduced Earnings Claim
Apr 25, 2022

California High Court May Take Another Look at Employer’s Liability for COVID-19 Contracted by Employee’s Family Member

In an important case that may define—at least in California—an employer’s responsibility for injuries sustained when an employee’s family member contracts COVID-19 as a result of an infection that is...

California High Court May Take Another Look at Employer’s Liability for COVID-19 Contracted by Employee’s Family Member California High Court May Take Another Look at Employer’s Liability for COVID-19 Contracted by Employee’s Family Member

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...