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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

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Feb 13, 2025

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)

Background On May 21, 1946, Kelly fell and injured his left knee in an accident which arose out of and in the course of his employment with the employer. He...

Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949) Throwback Thursday: Kelly v. Federal Shipbuilding & Dry Dock Co. (1949)
Feb 10, 2025

Florida Workers’ Comp Lien Includes Post-Settlement Benefits

A Florida appellate court has ruled that a workers’ compensation carrier’s statutory lien rights extend to all benefits paid through the date of equitable distribution, not merely those paid through...

Florida Workers’ Comp Lien Includes Post-Settlement Benefits Florida Workers’ Comp Lien Includes Post-Settlement Benefits
Feb 7, 2025

SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute

In Russell v. Wal-Mart Stores, Inc., 2025 S.C. LEXIS 13 (Jan. 29, 2025), the South Carolina Supreme Court reversed a Workers’ Compensation Commission ruling that denied an injured worker additional...

SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute SC Supreme Court Rebukes Comp Comm’n in Change of Condition Dispute
Feb 6, 2025

Throwback Thursday: Bailey v. American General Ins. Co. (1955)

The Case and Its Context The 1955 Texas Supreme Court decision in Bailey v. American General Insurance Co., 154 Tex. 430, 279 S.W.2d 315 (1955), represents a landmark in the...

Throwback Thursday: Bailey v. American General Ins. Co. (1955) Throwback Thursday: Bailey v. American General Ins. Co. (1955)
Feb 4, 2025

Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable

In a case of first impression, an Illinois appellate court has held that work-related pain alone—without accompanying structural change or worsening—can constitute a compensable aggravation of a pre-existing asymptomatic condition...

Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable Illinois: Work-Related Pain from Asymptomatic Preexisting Condition is Compensable
Feb 3, 2025

GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns

A Georgia appellate court recently reversed a state Workers’ Compensation Board decision that denied temporary total disability (TTD) benefits to an employee who refused light-duty work due to COVID-19 health...

GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns GA Court: Refusal of Light-Duty Work Might Be Justified By COVID-19 Health Concerns
Jan 30, 2025

Throwback Thursday: Whetro v. Awkerman (1970)

When Mother Nature Met Workers’ Compensation On Palm Sunday 1965, a devastating series of tornadoes tore through southern Michigan. Among the victims were two workers: Carl Whetro, injured when the...

Throwback Thursday: Whetro v. Awkerman (1970) Throwback Thursday: Whetro v. Awkerman (1970)
Jan 28, 2025

“Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer

An Ohio employer cannot be held liable under the doctrine of respondeat superior for an employee’s negligent driving during a commute to work, even where the employee might reasonably be...

“Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer “Traveling Employee” Exception Not Applicable in Third-Party Tort Action Against Ohio Employer
Jan 27, 2025

IL Supreme Court: Widow Can Sue in Tort Although Husband’s Exposure to Toxins Occurred Before 2019 Legislative Change

An Illinois widow may pursue a civil action against her deceased husband’s employer for his asbestos-related death, even though his exposure occurred decades before a 2019 amendment to the state’s...

IL Supreme Court: Widow Can Sue in Tort Although Husband’s Exposure to Toxins Occurred Before 2019 Legislative Change IL Supreme Court: Widow Can Sue in Tort Although Husband’s Exposure to Toxins Occurred Before 2019 Legislative Change
Jan 23, 2025

Throwback Thursday: Booker v. Duke Medical Center (1979)

Background In the late 1960s and early 1970s, Robert Booker worked as a laboratory technician at Duke Medical Center in Durham, North Carolina, performing routine chemical tests on blood specimens....

Throwback Thursday: Booker v. Duke Medical Center (1979) Throwback Thursday: Booker v. Duke Medical Center (1979)
Jan 20, 2025

No PTSD Benefits for NY City Bus Driver

Passenger’s Attack Just Part of Driver’s “Normal Work Environment” In Matter of Waddy v. Manhattan & Bronx Surface Tr. Auth., 2025 N.Y. App. Div. LEXIS 244 (3rd Dept. Jan. 16,...

No PTSD Benefits for NY City Bus Driver No PTSD Benefits for NY City Bus Driver
Jan 14, 2025

MN: Driver’s Co-Employee Immunity Doesn’t Shield Vehicle Owners From Liability

Yesterday, reversing a trial court’s decision granting defendant vehicle owners’ motion for summary judgment, in Niebuhr v. Sieberg, 2025 Minn. App. LEXIS 4 (Jan. 13, 2025), the Minnesota Court of...

MN: Driver’s Co-Employee Immunity Doesn’t Shield Vehicle Owners From Liability MN: Driver’s Co-Employee Immunity Doesn’t Shield Vehicle Owners From Liability

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...