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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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Sep 28, 2021

Illinois Court Nixes Jurisdiction When Injury and Employment Contract Were in Indiana

In an unpublished decision, an Illinois appellate court reversed a decision of a county circuit court confirming an award of workers’ compensation benefits by the state’s Workers’ Compensation Commission on...

Illinois Court Nixes Jurisdiction When Injury and Employment Contract Were in Indiana Illinois Court Nixes Jurisdiction When Injury and Employment Contract Were in Indiana
Sep 27, 2021

South Dakota Court “Borrows” Going and Coming Rule for Negligence Action

The Supreme Court of South Dakota recently affirmed a trial court’s decision that granted summary judgment to a municipality and a volunteer fire department on the basis that the department’s...

South Dakota Court “Borrows” Going and Coming Rule for Negligence Action South Dakota Court “Borrows” Going and Coming Rule for Negligence Action
Sep 24, 2021

Iowa Court Affirms PPD Award Where Effects of Knee Injury Extended Beyond the Leg

Stressing that a claimant’s “injury” and “impairment” are not necessarily equivalents, an Iowa appellate court affirmed a determination that an injured worker was entitled to permanent partial disability benefits; he...

Iowa Court Affirms PPD Award Where Effects of Knee Injury Extended Beyond the Leg Iowa Court Affirms PPD Award Where Effects of Knee Injury Extended Beyond the Leg
Sep 22, 2021

Catch 22 Prevents Florida Officer From Utilizing Presumption of Compensability

A Florida appellate court affirmed a decision by a judge of compensation claims that found a law enforcement officer was not entitled to the special presumption of compensability related to...

Catch 22 Prevents Florida Officer From Utilizing Presumption of Compensability Catch 22 Prevents Florida Officer From Utilizing Presumption of Compensability
Sep 21, 2021

Florida Court Construes One-Time Change of Physician Statute

Where an injured employee sought a one-time change of physician and, within the five-day period designated in § 440.13(2)(f), Fla. Stat., was first given a referral physician and appointment options...

Florida Court Construes One-Time Change of Physician Statute Florida Court Construes One-Time Change of Physician Statute
Sep 20, 2021

NY Claimant’s Service Upon Third-Party Administrator Was Not Service Upon the Carrier Itself

While it is often said that the procedural aspects of a workers’ compensation dispute are largely informal, with the parties not always being bound to the narrowest interpretations of notice...

NY Claimant’s Service Upon Third-Party Administrator Was Not Service Upon the Carrier Itself NY Claimant’s Service Upon Third-Party Administrator Was Not Service Upon the Carrier Itself
Sep 16, 2021

NY Court Says Collateral Estoppel Bars Injured Worker’s Subsequent Negligence Action Against Defendants

A New York appellate court affirmed a decision by a state trial court that granted defendants summary judgment in a negligence action filed against them related to the alleged malfunction...

NY Court Says Collateral Estoppel Bars Injured Worker’s Subsequent Negligence Action Against Defendants NY Court Says Collateral Estoppel Bars Injured Worker’s Subsequent Negligence Action Against Defendants
Sep 14, 2021

Res Judicata Does Not Bar KY Employee From Reopening Claim

Quoting Larson’s Workers’ Compensation Law, and stressing that the doctrine of res judicata should be applied differently in workers’ compensation cases than in the usual context of a judicial action,...

Res Judicata Does Not Bar KY Employee From Reopening Claim Res Judicata Does Not Bar KY Employee From Reopening Claim
Sep 13, 2021

SC Commission is Immune From Suit After Apparent Stumbling With Attorney’s Fee Lien

A South Carolina appellate court affirmed a decision by a state trial court that dismissed the civil action filed against the S.C. Workers’ Compensation Commission by a law firm who...

SC Commission is Immune From Suit After Apparent Stumbling With Attorney’s Fee Lien SC Commission is Immune From Suit After Apparent Stumbling With Attorney’s Fee Lien
Sep 2, 2021

Va. Employee’s Injuries Sustained While Moving Under Descending Door Are Compensable

In an opinion not designated for publication, the Court of Appeals of Virginia affirmed an award of workers’ compensation benefits to an employee of an auto dealership who sustained injuries...

Va. Employee’s Injuries Sustained While Moving Under Descending Door Are Compensable Va. Employee’s Injuries Sustained While Moving Under Descending Door Are Compensable
Sep 1, 2021

KY Supreme Court Says Statute Terminating Income Benefits at Age 70 is Constitutional

The Kentucky Supreme Court held the 2018 amendment to Ky. Rev. Stat. 342.730(4), which terminates workers’ compensation income benefits when the recipient reaches the age of 70 or four years...

KY Supreme Court Says Statute Terminating Income Benefits at Age 70 is Constitutional KY Supreme Court Says Statute Terminating Income Benefits at Age 70 is Constitutional
Aug 30, 2021

GA Worker’s Subsequent Fall at Home Was an Intervening Cause of Current Condition

A Georgia appellate court found that a state superior court erred when it reversed the State Board of Workers’ Compensation’s determination that an injured worker had recovered from a work-related...

GA Worker’s Subsequent Fall at Home Was an Intervening Cause of Current Condition GA Worker’s Subsequent Fall at Home Was an Intervening Cause of Current Condition

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.