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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 1, 2022

PA Employer’s Right to Subrogation is “Absolute”

Acknowledging that a trial court in a declaratory action had fixed the injured employee’s total damages in his third-party tort claim at almost $2 million, designating $1,500,000 of that total...

PA Employer’s Right to Subrogation is “Absolute” PA Employer’s Right to Subrogation is “Absolute”
Jan 31, 2022

IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit

The exclusive remedy provisions of the Illinois Workers' Compensation Act (Act)—820 ILCS 305/5(a), 11— do not extend to a general contractor who paid workers’ compensation insurance premiums and benefits for...

IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit
Jan 27, 2022

New Mexico Cannot Differentiate Between Secondary Mental Benefits and Secondary Physical Benefits

Capping secondary mental impairment benefits—pursuant to NMSA 1978, Section 52-1-41(C)(2015)—to the number of weeks allowable for the worker’s original physical injury [e.g., 150 weeks where the mental injury is secondary...

New Mexico Cannot Differentiate Between Secondary Mental Benefits and Secondary Physical Benefits New Mexico Cannot Differentiate Between Secondary Mental Benefits and Secondary Physical Benefits
Jan 25, 2022

Colorado Court Says Injuries Sustained En Route to Medical Appointment Not Always Compensable

Relying upon the “quasi-course of employment” concept set forth in Larson’s Workers’ Compensation Law, § 10.05, a division of the Court of Appeals of Colorado affirmed an order of the...

Colorado Court Says Injuries Sustained En Route to Medical Appointment Not Always Compensable Colorado Court Says Injuries Sustained En Route to Medical Appointment Not Always Compensable
Jan 21, 2022

Establishing “Personal Comfort” Activity Is Only Half the Battle, says OR Court

Stressing that the focus of the personal comfort doctrine was to determine if an employee’s actions occurred during the course of the employment, the Court of Appeals of Oregon held...

Establishing “Personal Comfort” Activity Is Only Half the Battle, says OR Court Establishing “Personal Comfort” Activity Is Only Half the Battle, says OR Court
Jan 20, 2022

NY Court Affirms Award for Flight Attendant’s Allergy to Uniforms

Illustrating that it is for the New York Workers’ Compensation Board to weigh the evidence, even when that evidence has been presented to a law judge hearing the case, a...

NY Court Affirms Award for Flight Attendant’s Allergy to Uniforms NY Court Affirms Award for Flight Attendant’s Allergy to Uniforms
Jan 19, 2022

NJ Librarian’s Parking Lot Injuries When Struck by Snowplow are Compensable

Yesterday, the Supreme Court of New Jersey, reversing a decision of the Superior Court, Appellate Division [see 466 N.J. Super. 160, 245 A.3d 1019 (App. Div. 2021)], found that serious injuries...

NJ Librarian’s Parking Lot Injuries When Struck by Snowplow are Compensable NJ Librarian’s Parking Lot Injuries When Struck by Snowplow are Compensable
Jan 18, 2022

PA Court Agrees Injuries Were Compensable under Personal Comfort Doctrine

Applying the personal comfort doctrine [see Larson’s Workers’ Compensation Law, § 21.01, et seq.], pursuant to which small, temporary departures from work to administer to personal comforts or convenience are...

PA Court Agrees Injuries Were Compensable under Personal Comfort Doctrine PA Court Agrees Injuries Were Compensable under Personal Comfort Doctrine
Jan 14, 2022

The Case of the Missing Case

In early January, one can reliably count on at least two things: first, that we’ll be bombarded by television commercials hawking diet aids, and second, that someone in the New...

The Case of the Missing Case The Case of the Missing Case
Jan 13, 2022

Delaware High Court Says Sinkhole Injuries Were Not Compensable

The Supreme Court of Delaware affirmed the denial of workers’ compensation benefits to a courthouse employee who sustained injuries in a sinkhole accident near—but not on the courthouse property [Browning...

Delaware High Court Says Sinkhole Injuries Were Not Compensable Delaware High Court Says Sinkhole Injuries Were Not Compensable
Jan 13, 2022

Opinion Mondays: Is California’s “Posse Law” Passe?

In a case involving an utterly bizarre fact pattern, as well as a legal battle stretching out over the bulk of a decade, the Supreme Court of California, in a 5-2 decision, held that a civil action for negligence and misrepresentation filed by two private citizens against...

Opinion Mondays: Is California’s “Posse Law” Passe? Opinion Mondays: Is California’s “Posse Law” Passe?
Jan 11, 2022

Post-Injury Felony Conviction Not a Factor in Determining PA Employee’s Earning Power

A Pennsylvania WCJ need not consider non-work-related injury limitations that were the result of actions that occurred after the work-related injury as part of a Pennsylvania injured employee’s “residual productive...

Post-Injury Felony Conviction Not a Factor in Determining PA Employee’s Earning Power Post-Injury Felony Conviction Not a Factor in Determining PA Employee’s Earning Power

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...