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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
May 22, 2025

Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975)

Tools, Timing, and Termination In Nails v. Market Tire Co., 29 Md. App. 154, 347 A.2d 564 (Md. Ct. Spec. App. 1975), the Maryland Court of Special Appeals addressed a...

Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975) Throwback Thursday: Nails v. Market Tire Co. (Md. Ct. Spec. App. 1975)

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Mar 13, 2025

Throwback Thursday: Snyder v. Michael’s Stores, Inc. (1997)

Exclusive Remedy and the Independent Injury Exception A cornerstone of workers’ compensation law is the exclusive remedy rule, which generally bars employees and their families from suing an employer in...

Throwback Thursday: Snyder v. Michael’s Stores, Inc. (1997) Throwback Thursday: Snyder v. Michael’s Stores, Inc. (1997)
Mar 12, 2025

Ohio Court Strikes Down Outdated Legal Doctrine in Permanent Disability Case

250312 Ohio Court Strikes Down Outdated Legal Doctrine in Permanent Disability Case Industrial Commission Ordered to Reevaluate Denied PTD Claim Ohio’s Tenth District Court of Appeals recently ruled that the...

Ohio Court Strikes Down Outdated Legal Doctrine in Permanent Disability Case Ohio Court Strikes Down Outdated Legal Doctrine in Permanent Disability Case
Mar 10, 2025

VA Truck Driver’s Assault Following Road Rage Incident Found Compensable

In a decision that reinforces Virginia’s approach to compensability under the state’s Workers’ Compensation Act (“the Act”), the Virginia Court of Appeals has affirmed an award of benefits to a...

VA Truck Driver’s Assault Following Road Rage Incident Found Compensable VA Truck Driver’s Assault Following Road Rage Incident Found Compensable
Mar 6, 2025

Throwback Thursday: Guidry v. Sline Industrial Painters, Inc. (1982)

Background On December 28, 1979, Alcide Guidry, a 53-year-old industrial painter, arrived at work as usual at 7:30 a.m. for Sline Industrial Painters. Assigned with a colleague to paint large...

Throwback Thursday: Guidry v. Sline Industrial Painters, Inc. (1982) Throwback Thursday: Guidry v. Sline Industrial Painters, Inc. (1982)
Mar 4, 2025

California Supreme Court Preserves Maritime Claims for Workers Excluded from LHWCA

In an important decision for maritime law and workers’ rights, the California Supreme Court has ruled that workers excluded from the federal Longshore and Harbor Workers’ Compensation Act (LHWCA) may...

California Supreme Court Preserves Maritime Claims for Workers Excluded from LHWCA California Supreme Court Preserves Maritime Claims for Workers Excluded from LHWCA
Mar 3, 2025

PA Court Rules on COVID-19 “E-Time” Payments in Workers’ Comp Case

In a recent Pennsylvania workers’ compensation case, the state’s Commonwealth Court ruled that pandemic-related “excused time” payments, such as Philadelphia’s “E-Time” program, do not constitute “payments in lieu of compensation”...

PA Court Rules on COVID-19 “E-Time” Payments in Workers’ Comp Case PA Court Rules on COVID-19 “E-Time” Payments in Workers’ Comp Case
Feb 27, 2025

Throwback Thursday: Waters v. William J. Taylor Co. (1916) – The Humanitarian Rescue Doctrine

Background In 1916, the New York Court of Appeals issued a groundbreaking decision that would fundamentally shape how workers’ compensation law treats rescue attempts. The case, Waters v. William J....

Throwback Thursday: Waters v. William J. Taylor Co. (1916) – The Humanitarian Rescue Doctrine Throwback Thursday: Waters v. William J. Taylor Co. (1916) – The Humanitarian Rescue Doctrine
Feb 26, 2025

Florida Court Nixes Worker’s Comp Award for Spouse’s Household Chores

Yesterday, in Girardin v. An Fort Myers Imps., LLC (2025 Fla. App. LEXIS 1292, Feb. 19, 2025), Florida’s First District Court of Appeal struck down an award for attendant care...

Florida Court Nixes Worker’s Comp Award for Spouse’s Household Chores Florida Court Nixes Worker’s Comp Award for Spouse’s Household Chores
Feb 20, 2025

Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job

Background In 1928, the Minnesota Supreme Court issued a decision that would help establish important principles about when off-premises lunch injuries fall within the scope of workers’ compensation coverage. The...

Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job Throwback Thursday: Krause v. Swartwood (1928) – When Lunch is Part of the Job
Feb 19, 2025

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence

In a decision that reinforces the potential consequences of misrepresenting one’s physical condition, a New York appellate court has upheld the permanent disqualification from wage replacement benefits of a workers’...

NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence NY Court Upholds Permanent Benefits Ban Based on Surveillance Evidence
Feb 18, 2025

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits

In an unpublished decision, a Kansas appellate court has struck down an employer’s attempt to deny workers’ compensation benefits to an employee who refused a drug test 18 days after...

Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits Drug Test Delay Dooms Kansas Employer’s Attempt to Deny Benefits
Feb 14, 2025

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim

In Matter of Tudor v. Whitehall Cent. Sch. Dist., 2025 N.Y. App. Div. LEXIS 827 (3d Dept., Feb. 13, 2025), the New York Appellate Division, Third Department, affirmed the state...

Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim Cautious Medical Testimony Dooms NY Teacher’s Stroke Claim

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...