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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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Jul 19, 2021

Ohio Home Health Aide’s Injuries Outside Client’s Residence Not Compensable

An Ohio appellate court affirmed the denial of workers’ compensation benefits to a home health care aide who sustained a T12 vertebrae compression fracture when she slipped and fell on...

Ohio Home Health Aide’s Injuries Outside Client’s Residence Not Compensable Ohio Home Health Aide’s Injuries Outside Client’s Residence Not Compensable
Jul 14, 2021

Virginia Worker’s Fall on Workplace Steps is Not Compensable

A Virginia appellate court, yet again reiterating the state’s version of the “actual risk rule” [see Larson’s Workers’ Compensation Law, § 3.04] affirmed a decision by the state’s Workers’ Compensation...

Virginia Worker’s Fall on Workplace Steps is Not Compensable Virginia Worker’s Fall on Workplace Steps is Not Compensable
Jul 12, 2021

AZ Police Officer’s PTSD Claim Fails Since Stress was not Unexpected

In a split decision, an Arizona appellate court affirmed a finding by the state’s Industrial Commission that a police officer failed to establish a compensable workers’ compensation claim based on...

AZ Police Officer’s PTSD Claim Fails Since Stress was not Unexpected AZ Police Officer’s PTSD Claim Fails Since Stress was not Unexpected
Jul 8, 2021

PA Court Says Janitor’s Fall Near Entrance of Building is Compensable

A Pennsylvania appellate court reversed a decision of a state workers’ compensation judge, affirmed by the state’s Board, that had denied workers’ compensation benefits to a janitor who sustained injuries...

PA Court Says Janitor’s Fall Near Entrance of Building is Compensable PA Court Says Janitor’s Fall Near Entrance of Building is Compensable
Jul 1, 2021

Illinois Court Stresses that Both Loaning and Borrowing Employers are Immune From Tort Liability

In an Illinois personal injury action filed by a temporary worker who had been assigned by a temporary staffing agency to a packaging company, both the “loaning” employer and the...

Illinois Court Stresses that Both Loaning and Borrowing Employers are Immune From Tort Liability Illinois Court Stresses that Both Loaning and Borrowing Employers are Immune From Tort Liability
Jun 29, 2021

NY Worker’s Claim Denied Where He Died Before Record Could be Established

A New York appellate court affirmed a decision by the state’s Workers’ Compensation Board that disallowed the claim of an employee who sought workers’ compensation benefits approximately one month after...

NY Worker’s Claim Denied Where He Died Before Record Could be Established NY Worker’s Claim Denied Where He Died Before Record Could be Established
Jun 28, 2021

“Roll the Video”: Surveillance Footage Supports NY Board’s Finding That Claimant Misrepresented Material Fact

A New York appellate court held that substantial evidence supported a decision by the state’s Workers’ Compensation Board disqualifying a workers’ compensation claimant from further benefits, based upon his misrepresentation...

“Roll the Video”: Surveillance Footage Supports NY Board’s Finding That Claimant Misrepresented Material Fact “Roll the Video”: Surveillance Footage Supports NY Board’s Finding That Claimant Misrepresented Material Fact
Jun 25, 2021

Self-Employed SC Roofer May Have Been Roofing Co.’s Employee

The Court of Appeals of South Carolina reversed, in part, a decision by the state’s Workers’ Compensation Appellate Panel that had found an injured roofer was an independent contractor—and not...

Self-Employed SC Roofer May Have Been Roofing Co.’s Employee Self-Employed SC Roofer May Have Been Roofing Co.’s Employee
Jun 24, 2021

MS Court Affirms Denial of Quadriplegic’s Settlement Agreement

A Mississippi appellate court affirmed a decision by the state’s Workers’ Compensation Commission that denied—without a hearing—an injured worker’s petition to settle and close out the medical portion of his...

MS Court Affirms Denial of Quadriplegic’s Settlement Agreement MS Court Affirms Denial of Quadriplegic’s Settlement Agreement
Jun 22, 2021

Colorado Hospital’s Action in Billing Claimant for Medical Services Warranted Penalty, But Not as a “Continuing” Offense

A Colorado appellate court affirmed the imposition of a $750 penalty for each of eight instances in which a hospital sent invoices to a worker who had sustained work-related injuries...

Colorado Hospital’s Action in Billing Claimant for Medical Services Warranted Penalty, But Not as a “Continuing” Offense Colorado Hospital’s Action in Billing Claimant for Medical Services Warranted Penalty, But Not as a “Continuing” Offense
Jun 21, 2021

NY Law Firm’s $52K Fee Request Will be Reconsidered by Board

In a relatively unusual move, the Appellate Division of the Supreme Court of New York (Third Department) vacated its October 8, 2020 decision [reported at 187 A.D.3d 1297, 132 N.Y.S.3d...

NY Law Firm’s $52K Fee Request Will be Reconsidered by Board NY Law Firm’s $52K Fee Request Will be Reconsidered by Board
Jun 17, 2021

NY Grave Digger’s Intentional Distress Claim Fails

A New York appellate court affirmed a trial court’s order granting an employer’s motion for summary judgment in a case in which a former employee—a grave digger—contended he had sustained...

NY Grave Digger’s Intentional Distress Claim Fails NY Grave Digger’s Intentional Distress Claim Fails

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.