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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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Dec 9, 2021

For Limitations Purposes, a NC Death Claim Cannot Piggy-Back Onto Deceased Employee’s Original Filing

A divided panel of the North Carolina Court of Appeals recently affirmed a decision by the state’s Industrial Commission that had found it lacked jurisdiction to hear a widow’s death...

For Limitations Purposes, a NC Death Claim Cannot Piggy-Back Onto Deceased Employee’s Original Filing For Limitations Purposes, a NC Death Claim Cannot Piggy-Back Onto Deceased Employee’s Original Filing
Dec 7, 2021

PA Police Officer Awarded Benefits for PTSD After “No-Holds-Barred” Meeting

In an unreported opinion, the Commonwealth Court of Pennsylvania affirmed an award of total disability benefits to former police officer for a psychological injury in the form of PTDS, depression,...

PA Police Officer Awarded Benefits for PTSD After “No-Holds-Barred” Meeting PA Police Officer Awarded Benefits for PTSD After “No-Holds-Barred” Meeting
Dec 6, 2021

Oregon Software Worker Fails to Establish Mental Disorder Claim

Illustrating the substantial barrier that many Oregon claimants contend has been erected via the combination of the state’s “clear and convincing evidence” standard and its “major contributing cause” requirement [see...

Oregon Software Worker Fails to Establish Mental Disorder Claim Oregon Software Worker Fails to Establish Mental Disorder Claim
Dec 2, 2021

Slowly Plods the Tortoise: Workcompwriter Celebrates 1,000 Posts

Launch the balloons! Break out the kazoos! Almost exactly ten years ago—on December 14, 2011—I posted my first offering on this website (to see it, click here). It discussed a...

Slowly Plods the Tortoise: Workcompwriter Celebrates 1,000 Posts Slowly Plods the Tortoise: Workcompwriter Celebrates 1,000 Posts
Nov 30, 2021

Full-Time, Seasonal Work Sinks Missouri Worker’s Second Injury Fund Claim

Where a Missouri employee was able to work on a full-time, seasonable basis following a second work-related injury, the Missouri Commission did not err in finding that the employee had...

Full-Time, Seasonal Work Sinks Missouri Worker’s Second Injury Fund Claim Full-Time, Seasonal Work Sinks Missouri Worker’s Second Injury Fund Claim
Nov 29, 2021

Oregon Employee’s Slip and Fall Claim in “Annex Parking Area” Not Barred by Going and Coming Rule

Construing the “parking lot” exception to the standard going and coming rule, an Oregon appellate court affirmed an award of benefits to a dental hygienist who sustained injuries when she...

Oregon Employee’s Slip and Fall Claim in “Annex Parking Area” Not Barred by Going and Coming Rule Oregon Employee’s Slip and Fall Claim in “Annex Parking Area” Not Barred by Going and Coming Rule
Nov 22, 2021

Waiting 19 Months to Seek Medical Treatment Proves Fatal to NY Claims Examiner’s Case

A New York appellate court affirmed a decision by the state’s Workers’ Compensation Board that denied benefits to a claims examiner who alleged that she had sustained injuries to her...

Waiting 19 Months to Seek Medical Treatment Proves Fatal to NY Claims Examiner’s Case Waiting 19 Months to Seek Medical Treatment Proves Fatal to NY Claims Examiner’s Case
Nov 16, 2021

Florida’s Second DCA Reverses Itself; Public Utility Was “Contractor” as to its Maintenance Efforts

Following Tampa Electric Company's motion for rehearing regarding its October 20, 2020 decision, in which Florida’s Second District Court of Appeal had held that the public utility company’s obligation to...

Florida’s Second DCA Reverses Itself; Public Utility Was “Contractor” as to its Maintenance Efforts Florida’s Second DCA Reverses Itself; Public Utility Was “Contractor” as to its Maintenance Efforts
Nov 11, 2021

Alaska Supreme Court Says Estate’s Wrongful Death Action is Barred by Exclusivity Even When Comp Benefits are Limited to Burial Expenses

Addressing a difficult factual pattern for the second time, the Supreme Court of Alaska affirmed a trial court’s decision that had granted summary judgment in favor of a general contractor...

Alaska Supreme Court Says Estate’s Wrongful Death Action is Barred by Exclusivity Even When Comp Benefits are Limited to Burial Expenses Alaska Supreme Court Says Estate’s Wrongful Death Action is Barred by Exclusivity Even When Comp Benefits are Limited to Burial Expenses
Nov 9, 2021

Battle of the Forms: NY Board Abuses Discretion in Failing to Reopen Claim

Where there was a clear discrepancy between the schedule loss of use (SLU) percentage indicated on the face of a surgeon’s C-4.3 form (Doctor’s Report of Maximum Medical Improvement/Permanent Impairment)...

Battle of the Forms: NY Board Abuses Discretion in Failing to Reopen Claim Battle of the Forms: NY Board Abuses Discretion in Failing to Reopen Claim
Nov 8, 2021

Utah High Court Hints that Intentional Tort Exception to Exclusivity Might Not Apply to Occupational Disease Claims

Observing that Utah has recognized the intentional tort exception to exclusivity in cases falling under the state’s Workers’ Compensation Act (WCA), but had not (yet) extended the exception to cases...

Utah High Court Hints that Intentional Tort Exception to Exclusivity Might Not Apply to Occupational Disease Claims Utah High Court Hints that Intentional Tort Exception to Exclusivity Might Not Apply to Occupational Disease Claims
Nov 2, 2021

Kentucky High Court Construes Mental Injury Statute and Affirms Award

Acknowledging that pursuant to KRS 342.0011(1), Kentucky does not allow recovery for work-related psychological injuries unless they are the “direct result” of a physical injury [emphasis added], the Supreme Court...

Kentucky High Court Construes Mental Injury Statute and Affirms Award Kentucky High Court Construes Mental Injury Statute and Affirms Award

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...