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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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Jun 16, 2021

NY Court Examines Applicability of Back-Dated Indemnification Agreement

A New York appellate court affirmed a trial court’s decision denying that portion of an employer/third-party defendant’s motion seeking dismissal of a contractual indemnification claim filed against it by a...

NY Court Examines Applicability of Back-Dated Indemnification Agreement NY Court Examines Applicability of Back-Dated Indemnification Agreement
Jun 15, 2021

NY Jury Must Consider Whether Defendant was Special Employee Entitled to Exclusive Remedy Defense

A New York appellate court affirmed a trial court’s determination that there were issues of fact as to whether a defendant was the special employee of plaintiff’s employer so as...

NY Jury Must Consider Whether Defendant was Special Employee Entitled to Exclusive Remedy Defense NY Jury Must Consider Whether Defendant was Special Employee Entitled to Exclusive Remedy Defense
Jun 10, 2021

Action Filed Under NJ’s Discrimination Law Not Barred by Exclusive Remedy Rule

The Supreme Court of New Jersey, examining the intersection between the state’s Worker’s Compensation Act (WCA) and its Law Against Discrimination (LAD), held that a teacher’s LAD claim alleging that...

Action Filed Under NJ’s Discrimination Law Not Barred by Exclusive Remedy Rule Action Filed Under NJ’s Discrimination Law Not Barred by Exclusive Remedy Rule
Jun 9, 2021

Intentional Injury Action Against Co-Employees Fails Under Alabama’s Substantially Certain Rule

Applying Alabama’s intentional injury exception to the exclusive remedy rule, the Supreme Court of Alabama affirmed a trial court’s decision granting two co-employee defendants summary judgment in a civil action...

Intentional Injury Action Against Co-Employees Fails Under Alabama’s Substantially Certain Rule Intentional Injury Action Against Co-Employees Fails Under Alabama’s Substantially Certain Rule
Jun 8, 2021

ND High Court Stresses That Heart Attacks Only Compensable When Caused by Unusual Stress

Construing the state’s special statute limiting the compensability of heart attacks, stroke, and physical injury caused by mental stimulus, a divided Supreme Court of North Dakota reversed an ALJ’s decision...

ND High Court Stresses That Heart Attacks Only Compensable When Caused by Unusual Stress ND High Court Stresses That Heart Attacks Only Compensable When Caused by Unusual Stress
Jun 7, 2021

Ex Parte Communications Sink NY Death Benefits Claim

Showing just how serious New York courts take the issue of ex parte communications between counsel and medical experts, a New York appellate court recently affirmed an order by the...

Ex Parte Communications Sink NY Death Benefits Claim Ex Parte Communications Sink NY Death Benefits Claim
Jun 3, 2021

NY Claimant’s Failure to Disclose Gambling Activities Constitutes § 114-a Violation

A New York appellate court affirmed a decision by the state’s Workers’ Compensation Board that not only imposed the mandatory penalty rescinding the claimant’s award of workers’ compensation benefits, but...

NY Claimant’s Failure to Disclose Gambling Activities Constitutes § 114-a Violation NY Claimant’s Failure to Disclose Gambling Activities Constitutes § 114-a Violation
Jun 2, 2021

$15K “Fine” Against Florida Comp Insurer Not Supported by Evidence

In an appeal and cross-appeal from an order granting sanctions against an insurer for failure to provide orthopedic treatment to an injured worker, a Florida appellate court held that a...

$15K “Fine” Against Florida Comp Insurer Not Supported by Evidence $15K “Fine” Against Florida Comp Insurer Not Supported by Evidence
Jun 1, 2021

PA Court: Carefully Planned Suicide Still Compensable

Decision is Consistent with Majority Rule In a holding that is consistent with the dominant rule among American jurisdictions, a Pennsylvania appellate court recently affirmed a Board decision that awarded...

PA Court: Carefully Planned Suicide Still Compensable PA Court: Carefully Planned Suicide Still Compensable
May 27, 2021

Arkansas Horse-Racing Employee’s Leap From Burning Stable Was Not Compensable

Applying Arkansas’ relatively narrow employment-related rule, which excludes compensation for an injury which was inflicted upon the employee at a time when employment services were not being performed [see Ark....

Arkansas Horse-Racing Employee’s Leap From Burning Stable Was Not Compensable Arkansas Horse-Racing Employee’s Leap From Burning Stable Was Not Compensable
May 26, 2021

“Odd-Lot”-Like Theory Works in Reverse to Limit Wage Loss Award for NY Claimant

Observing that in determining a claimant’s loss of wage-earning capacity, the New York Workers’ Compensation Board may consider claimant’s functional capabilities, as well as vocational issues (claimant’s age, education, training,...

“Odd-Lot”-Like Theory Works in Reverse to Limit Wage Loss Award for NY Claimant “Odd-Lot”-Like Theory Works in Reverse to Limit Wage Loss Award for NY Claimant
May 25, 2021

NY Board Has Broad Discretion in Reviewing § 114-a Issues

In a decision that illustrates the tremendous breadth of discretion allowed to the New York Workers’ Compensation Board, a state appellate court affirmed a Board decision—in spite of findings by...

NY Board Has Broad Discretion in Reviewing § 114-a Issues NY Board Has Broad Discretion in Reviewing § 114-a Issues

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.