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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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Jan 10, 2022

NC Court Construes State’s “Injury by Accident” Requirement

Construing N.C. Gen. Stat. § 97-2(6), which defines “injury” to mean “only injury by accident arising out of and in the course of the employment” [emphasis added], the Court of...

NC Court Construes State’s “Injury by Accident” Requirement NC Court Construes State’s “Injury by Accident” Requirement
Jan 6, 2022

The Top 10 Bizarre Workers’ Comp Cases for 2021

Copyright 2022. Thomas A. Robinson. All rights reserved. This post may not be reproduced, in whole or in part, in any form or format, without the express written consent of...

The Top 10 Bizarre Workers’ Comp Cases for 2021 The Top 10 Bizarre Workers’ Comp Cases for 2021
Jan 4, 2022

Florida Court Agrees Firefighter Not Entitled to Reimbursement for Back Surgery

A Florida appellate court has affirmed a decision of a Judge of Compensation Claims (JCC) holding that an injured firefighter was not entitled to reimbursement for additional surgical expenses related...

Florida Court Agrees Firefighter Not Entitled to Reimbursement for Back Surgery Florida Court Agrees Firefighter Not Entitled to Reimbursement for Back Surgery
Jan 3, 2022

NY Board Abused Discretion in Failing to Allow Carrier’s Review Application

In a claim tangental to a highly-publicized 2019 indictment for alleged workers’ compensation fraud, a New York appellate court held that the state’s Workers’ Compensation Board abused its discretion when...

NY Board Abused Discretion in Failing to Allow Carrier’s Review Application NY Board Abused Discretion in Failing to Allow Carrier’s Review Application
Dec 29, 2021

NY Firefighter Successfully Proved PTSD Claim Based Upon Multiple Gruesome Incidents

Noting that a medical opinion need not be expressed with absolute medical certainty as long as it signified a probability of the underlying cause that was supported by a rational...

NY Firefighter Successfully Proved PTSD Claim Based Upon Multiple Gruesome Incidents NY Firefighter Successfully Proved PTSD Claim Based Upon Multiple Gruesome Incidents
Dec 27, 2021

PA Supreme Court “Corrects” Long-Standing Rule Regarding Award of Attorney’s Fees Against Employer Who Reasonably Contests Issues

In a decision that is turning heads in the Keystone State, the Supreme Court of Pennsylvania, stressing the importance differences between two words—“shall” and “may”—reversed a decision by the state’s...

PA Supreme Court “Corrects” Long-Standing Rule Regarding Award of Attorney’s Fees Against Employer Who Reasonably Contests Issues PA Supreme Court “Corrects” Long-Standing Rule Regarding Award of Attorney’s Fees Against Employer Who Reasonably Contests Issues
Dec 24, 2021

California Comp Act Does Not Bar COVID-19 Wrongful Death Claim

In an important decision that is certain to garner attention well beyond California’s borders, a California appellate court denied a petition for writ of mandate filed by an employer who...

California Comp Act Does Not Bar COVID-19 Wrongful Death Claim California Comp Act Does Not Bar COVID-19 Wrongful Death Claim
Dec 21, 2021

IL Supreme Court Sidesteps Important Issue on Technical Grounds

Dodging an issue that had spawned multiple amicus curiae briefs regarding an interesting (and important) question—whether an employee’s representation in a workers’ compensation settlement agreement that he had only suffered...

IL Supreme Court Sidesteps Important Issue on Technical Grounds IL Supreme Court Sidesteps Important Issue on Technical Grounds
Dec 16, 2021

Iowa Court Affirms Denial of Death Benefits in Suicide Case

An Iowa appellate court affirmed a district court’s decision affirming the denial of death benefits to a widow whose husband committed suicide mere hours after he had been terminated from...

Iowa Court Affirms Denial of Death Benefits in Suicide Case Iowa Court Affirms Denial of Death Benefits in Suicide Case
Dec 14, 2021

Federal Court Dismisses Racially-Based IIED Suit Filed Against Co-Employee

A federal district court, construing Missouri law, dismissed a civil action filed by one employee against another alleging negligent infliction of emotional distress (“NIED”) and intentional infliction of emotional distress...

Federal Court Dismisses Racially-Based IIED Suit Filed Against Co-Employee Federal Court Dismisses Racially-Based IIED Suit Filed Against Co-Employee
Dec 13, 2021

Arkansas Court Affirms Revocation of Pharmacy License in Pain Cream Cases

A divided division of the Arkansas Court of Appeals has affirmed a decision by the state’s Board of Pharmacy that revoked the permit and license of a pharmacy and an...

Arkansas Court Affirms Revocation of Pharmacy License in Pain Cream Cases Arkansas Court Affirms Revocation of Pharmacy License in Pain Cream Cases
Dec 10, 2021

SC Appellate Court Chides Commission for Summarily Dismissing Appeal

In a stinging decision, the Court of Appeals of South Carolina ruled that the state’s Workers’ Compensation Commission had abused its discretion in summarily dismissing the appeal by an insurance...

SC Appellate Court Chides Commission for Summarily Dismissing Appeal SC Appellate Court Chides Commission for Summarily Dismissing Appeal

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...