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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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Aug 26, 2021

Delaware Board Must Decide if COVID-Related Claim is Compensable

The Superior Court of Delaware (New Castle) held that the issue of whether an employee’s fatal COVID-19 infection was an injury or occupational disease must be determined by the state’s...

Delaware Board Must Decide if COVID-Related Claim is Compensable Delaware Board Must Decide if COVID-Related Claim is Compensable
Aug 24, 2021

Oregon Employee Recovers Benefits Following Explosion of Energy Drink

In a case with a rather bizarre fact pattern, an Oregon appellate court affirmed a decision by the state’s Workers’ Compensation Board that awarded benefits to a painter who sustained...

Oregon Employee Recovers Benefits Following Explosion of Energy Drink Oregon Employee Recovers Benefits Following Explosion of Energy Drink
Aug 23, 2021

SD Worker’s Letter Asking for “Review of Benefits” Was Inadequate to Toll Limitations Statute

Acknowledging the relative informality within the South Dakota workers’ compensation laws as well as the public policy that the state’s Workers’ Compensation Act and its rules should be construed liberally...

SD Worker’s Letter Asking for “Review of Benefits” Was Inadequate to Toll Limitations Statute SD Worker’s Letter Asking for “Review of Benefits” Was Inadequate to Toll Limitations Statute
Aug 19, 2021

MN High Court Says Injured Worker Failed to Establish Exception Allowing Long-Term Opioid Use

In a carefully crafted decision dealing with a chronic problem both within and without the workers’ compensation world—long-term opioid use—the Supreme Court of Minnesota held an injured workers treatment with...

MN High Court Says Injured Worker Failed to Establish Exception Allowing Long-Term Opioid Use MN High Court Says Injured Worker Failed to Establish Exception Allowing Long-Term Opioid Use
Aug 17, 2021

Delaware Worker’s Running in Workplace Bars Claim for Injuries

Construing 19 Del. C. § 2353(b), which bars an employee’s right to compensation for an injury if the injury results, inter alia, from “the employee’s deliberate and reckless indifference to...

Delaware Worker’s Running in Workplace Bars Claim for Injuries Delaware Worker’s Running in Workplace Bars Claim for Injuries
Aug 9, 2021

Utah IME Physician May Not Be Sued by Workers’ Comp Claimant

Finding that a physician-patient relationship did not exist between a doctor hired by the workers’ compensation carrier to perform an independent medical examination of the claimant, the Supreme Court of...

Utah IME Physician May Not Be Sued by Workers’ Comp Claimant Utah IME Physician May Not Be Sued by Workers’ Comp Claimant
Aug 5, 2021

Half of Virginia Claimant’s PPD Apportioned to Pre-Existing Condition

In a decision not designated for publication, a Virginia appellate court affirmed a finding of the state’s Workers’ Compensation Commission that an injured employee’s work-related accident had caused only a...

Half of Virginia Claimant’s PPD Apportioned to Pre-Existing Condition Half of Virginia Claimant’s PPD Apportioned to Pre-Existing Condition
Jul 29, 2021

Virginia Claimant Did Not Violate Known Safety Rule in Connection with Injury

Construing Virginia’s intentional violation of a known safety rule statute [Va. Code § 65.2-306(A)], a state appellate court affirmed an award of workers’ compensation benefits to an employee who sustained...

Virginia Claimant Did Not Violate Known Safety Rule in Connection with Injury Virginia Claimant Did Not Violate Known Safety Rule in Connection with Injury
Jul 27, 2021

NY Court Agrees Claimant’s Injuries Occurred Within “Gray Area” of Employment

Reiterating New York’s special “gray area” rule, pursuant to which injuries sustained in public areas near the employment—but not on the employer’s premises—are nevertheless compensable where the risks of street...

NY Court Agrees Claimant’s Injuries Occurred Within “Gray Area” of Employment NY Court Agrees Claimant’s Injuries Occurred Within “Gray Area” of Employment
Jul 26, 2021

Surviving Spouse Fails to Show Causal Connection Between NY Injury and Decedent’s Subsequent Death

A New York appellate court affirmed a determination by the state’s Workers’ Compensation Board that the surviving spouse of a deceased worker failed to establish—by competent medical evidence—that his wife’s...

Surviving Spouse Fails to Show Causal Connection Between NY Injury and Decedent’s Subsequent Death Surviving Spouse Fails to Show Causal Connection Between NY Injury and Decedent’s Subsequent Death
Jul 23, 2021

PA Claimant’s Benefits Terminated: 18 Months of Home Remedies Did Not Constitute Medical Treatment

The Pennsylvania Commonwealth Court held a WCJ appropriately relied upon the medical opinion of the employer’s examining physician in which the doctor opined that the workers’ compensation claimant had made...

PA Claimant’s Benefits Terminated: 18 Months of Home Remedies Did Not Constitute Medical Treatment PA Claimant’s Benefits Terminated: 18 Months of Home Remedies Did Not Constitute Medical Treatment
Jul 20, 2021

NY Worker Fails to Establish Claim for Lyme Disease

A New York appellate court affirmed a decision by the state’s Workers’ Compensation Board that denied a claim for consequential Lyme disease in spite of an opinion offered by an...

NY Worker Fails to Establish Claim for Lyme Disease NY Worker Fails to Establish Claim for Lyme Disease

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.