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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
May 22, 2025

Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975)

Tools, Timing, and Termination In Nails v. Market Tire Co., 29 Md. App. 154, 347 A.2d 564 (Md. Ct. Spec. App. 1975), the Maryland Court of Special Appeals addressed a...

Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975) Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975)

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Apr 8, 2025

NC Court Rejects Tort Claim for Workplace Fatality

In a decision that underscores the high bar for pursuing civil remedies alongside a workers’ compensation claim, the North Carolina Court of Appeals recently affirmed summary judgment against the estate...

NC Court Rejects Tort Claim for Workplace Fatality NC Court Rejects Tort Claim for Workplace Fatality
Apr 7, 2025

PA Court Upholds Medical-Only Notice of Compensation Payable Issued by Mistake

What happens when a claims adjuster clicks the wrong box in the third-party administrator’s software—and it accidentally binds the employer to a workers’ compensation claim? In City of Philadelphia v....

PA Court Upholds Medical-Only Notice of Compensation Payable Issued by Mistake PA Court Upholds Medical-Only Notice of Compensation Payable Issued by Mistake
Apr 3, 2025

Throwback Thursday: Graybeal v. Board of Supervisors (1975)

Rethinking the Limits of “Course of Employment” In traditional workers’ compensation doctrine, an injury must not only “arise out of” employment but also occur “in the course of” employment. Courts...

Throwback Thursday: Graybeal v. Board of Supervisors (1975) Throwback Thursday: Graybeal v. Board of Supervisors (1975)
Apr 1, 2025

Rear-Ended While Intoxicated—and Still Covered: A Careful Reading of NY’s § 10(1)

In a bizarre case that turned on the precise wording of N.Y. Workers' Comp. Law § 10(1), a state appellate court affirmed a Board decision awarding benefits to a claimant...

Rear-Ended While Intoxicated—and Still Covered: A Careful Reading of NY’s § 10(1) Rear-Ended While Intoxicated—and Still Covered: A Careful Reading of NY’s § 10(1)
Mar 31, 2025

Independent Contractor Peace Officer Not Covered by Workers’ Compensation

Texas Court Applies Motor Carrier Exception to General Contractor Rule A Texas appellate court has affirmed a trial court’s take-nothing judgment in favor of Texas Mutual Insurance Company, concluding that...

Independent Contractor Peace Officer Not Covered by Workers’ Compensation Independent Contractor Peace Officer Not Covered by Workers’ Compensation
Mar 27, 2025

Throwback Thursday: New York Central R. Co. v. White (1917)

Background The early 20th century saw a seismic shift in how American society approached workplace injuries. Before the widespread adoption of workers' compensation laws, injured workers typically had to sue...

Throwback Thursday: New York Central R. Co. v. White (1917) Throwback Thursday: New York Central R. Co. v. White (1917)
Mar 26, 2025

Routine Disciplinary Meeting Not a Compensable “Accident” Under NC’ Comp Act

In Muse v. Daimler Trucks N. Am., 2025 N.C. App. LEXIS 113 (Mar. 19, 2025), the North Carolina Court of Appeals affirmed the Industrial Commission’s denial of workers’ compensation benefits...

Routine Disciplinary Meeting Not a Compensable “Accident” Under NC’ Comp Act Routine Disciplinary Meeting Not a Compensable “Accident” Under NC’ Comp Act
Mar 25, 2025

CT Supreme Court: Temporary Partial Benefits May Continue After MMI

In what I think is an unprecedented decision, the Connecticut Supreme Court has held that a workers’ compensation commissioner may award ongoing temporary partial incapacity benefits even after a claimant...

CT Supreme Court: Temporary Partial Benefits May Continue After MMI CT Supreme Court: Temporary Partial Benefits May Continue After MMI
Mar 24, 2025

PA Supreme Court Affirms Cannabidiol Reimbursement for Injured Attorney

In a closely watched decision, the Supreme Court of Pennsylvania affirmed the Commonwealth Court’s ruling that a workers’ compensation claimant may be reimbursed for the cost of physician-prescribed cannabidiol (CBD)...

PA Supreme Court Affirms Cannabidiol Reimbursement for Injured Attorney PA Supreme Court Affirms Cannabidiol Reimbursement for Injured Attorney
Mar 20, 2025

Throwback Thursday: Correa v. Waymouth Farms, Inc. (2003)

Background In 2000, Fernando Correa, an undocumented worker employed at Waymouth Farms, Inc., suffered a back injury while lifting a box in the company’s warehouse. His employer initially accepted the...

Throwback Thursday: Correa v. Waymouth Farms, Inc. (2003) Throwback Thursday: Correa v. Waymouth Farms, Inc. (2003)
Mar 18, 2025

NY Appellate Court Reverses Board’s Decision in Death Benefits Case

In Matter of Hanson v. General Electric Co., 2025 N.Y. App. Div. LEXIS 1397 (3d Dept. Mar. 13, 2025), a New York appellate court reversed the Workers’ Compensation Board’s decision...

NY Appellate Court Reverses Board’s Decision in Death Benefits Case NY Appellate Court Reverses Board’s Decision in Death Benefits Case
Mar 17, 2025

California Court Bars Lawsuit Over Volunteer’s Death

In Kuo v. Dublin Unified School District, 2025 Cal. App. LEXIS 147 (Mar. 12, 2025), the First Appellate District (Division Four) of the California Court of Appeal held that because...

California Court Bars Lawsuit Over Volunteer’s Death California Court Bars Lawsuit Over Volunteer’s Death

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...