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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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Feb 25, 2022

NY Board Errs in Setting Disablement Date for Repetitive Stress Injury

A decision by the New York Workers’ Compensation Board that a claimant should have been aware of the work-related nature of his back pain and injury in June 2017, at...

NY Board Errs in Setting Disablement Date for Repetitive Stress Injury NY Board Errs in Setting Disablement Date for Repetitive Stress Injury
Feb 24, 2022

Florida Court Re-examines Valcourt-Williams “Increased Risk” Analysis

A Florida appellate court held that a state JCC had erred when the JCC denied compensability of a claim in which an employee suffered an unexplained fall as she walked...

Florida Court Re-examines Valcourt-Williams “Increased Risk” Analysis Florida Court Re-examines Valcourt-Williams “Increased Risk” Analysis
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

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...