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Jul 21, 2026

Utah High Court: Suspension, Not Dismissal, Is the Only Sanction for Obstructing an IME

Statute’s Specific Remedy Overrides Rule 37 Discovery Sanctions, Even After Three Failed Medical Exams The Supreme Court of Utah has held that dismissal is not an available sanction for a...

Utah High Court: Suspension, Not Dismissal, Is the Only Sanction for Obstructing an IME Utah High Court: Suspension, Not Dismissal, Is the Only Sanction for Obstructing an IME
Jul 16, 2026

Personal Comfort Doctrine Reaches a Formal, Unpaid Break

PA Court Finds a 15-Minute Break’s Brevity Outweighs Its Formality The Commonwealth Court of Pennsylvania recently affirmed an award of workers’ compensation benefits to a pharmacy technician struck by a...

Personal Comfort Doctrine Reaches a Formal, Unpaid Break Personal Comfort Doctrine Reaches a Formal, Unpaid Break
Jul 14, 2026

Trucker’s Retaliation Claim Runs Aground in His Own Hay Field

Idaho Federal Court Finds Surveillance and a Full-Duty Release Defeat Workers' Comp Retaliatory Discharge Claim The U.S. District Court for the District of Idaho recently granted summary judgment for a...

Trucker’s Retaliation Claim Runs Aground in His Own Hay Field Trucker’s Retaliation Claim Runs Aground in His Own Hay Field
Jul 13, 2026

FL High Court Rejects Motive Requirement for Workplace Assault Claims

Risk-Exposure Evidence Alone Can Establish the Causal Link, Justices Hold Last Thursday, In a unanimous decision authored by Justice Muñiz, the Supreme Court of Florida held that a workplace assault...

FL High Court Rejects Motive Requirement for Workplace Assault Claims FL High Court Rejects Motive Requirement for Workplace Assault Claims

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Feb 2, 2022

Judicial Estoppel Bars NY Defendants’ Exclusive Remedy Defense

In a divided decision, a New York appellate court held that where a Manpower, Inc. temporary worker was assigned to conduct inventory control at a pharmaceutical plant operated by two...

Judicial Estoppel Bars NY Defendants’ Exclusive Remedy Defense Judicial Estoppel Bars NY Defendants’ Exclusive Remedy Defense
Feb 1, 2022

PA Employer’s Right to Subrogation is “Absolute”

Acknowledging that a trial court in a declaratory action had fixed the injured employee’s total damages in his third-party tort claim at almost $2 million, designating $1,500,000 of that total...

PA Employer’s Right to Subrogation is “Absolute” PA Employer’s Right to Subrogation is “Absolute”
Jan 31, 2022

IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit

The exclusive remedy provisions of the Illinois Workers' Compensation Act (Act)—820 ILCS 305/5(a), 11— do not extend to a general contractor who paid workers’ compensation insurance premiums and benefits for...

IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit IL Contractor Who Provides Coverage for Subcontractor’s Workers Not Immune From Suit
Jan 27, 2022

New Mexico Cannot Differentiate Between Secondary Mental Benefits and Secondary Physical Benefits

Capping secondary mental impairment benefits—pursuant to NMSA 1978, Section 52-1-41(C)(2015)—to the number of weeks allowable for the worker’s original physical injury [e.g., 150 weeks where the mental injury is secondary...

New Mexico Cannot Differentiate Between Secondary Mental Benefits and Secondary Physical Benefits New Mexico Cannot Differentiate Between Secondary Mental Benefits and Secondary Physical Benefits
Jan 25, 2022

Colorado Court Says Injuries Sustained En Route to Medical Appointment Not Always Compensable

Relying upon the “quasi-course of employment” concept set forth in Larson’s Workers’ Compensation Law, § 10.05, a division of the Court of Appeals of Colorado affirmed an order of the...

Colorado Court Says Injuries Sustained En Route to Medical Appointment Not Always Compensable Colorado Court Says Injuries Sustained En Route to Medical Appointment Not Always Compensable
Jan 21, 2022

Establishing “Personal Comfort” Activity Is Only Half the Battle, says OR Court

Stressing that the focus of the personal comfort doctrine was to determine if an employee’s actions occurred during the course of the employment, the Court of Appeals of Oregon held...

Establishing “Personal Comfort” Activity Is Only Half the Battle, says OR Court Establishing “Personal Comfort” Activity Is Only Half the Battle, says OR Court
Jan 20, 2022

NY Court Affirms Award for Flight Attendant’s Allergy to Uniforms

Illustrating that it is for the New York Workers’ Compensation Board to weigh the evidence, even when that evidence has been presented to a law judge hearing the case, a...

NY Court Affirms Award for Flight Attendant’s Allergy to Uniforms NY Court Affirms Award for Flight Attendant’s Allergy to Uniforms
Jan 19, 2022

NJ Librarian’s Parking Lot Injuries When Struck by Snowplow are Compensable

Yesterday, the Supreme Court of New Jersey, reversing a decision of the Superior Court, Appellate Division [see 466 N.J. Super. 160, 245 A.3d 1019 (App. Div. 2021)], found that serious injuries...

NJ Librarian’s Parking Lot Injuries When Struck by Snowplow are Compensable NJ Librarian’s Parking Lot Injuries When Struck by Snowplow are Compensable
Jan 18, 2022

PA Court Agrees Injuries Were Compensable under Personal Comfort Doctrine

Applying the personal comfort doctrine [see Larson’s Workers’ Compensation Law, § 21.01, et seq.], pursuant to which small, temporary departures from work to administer to personal comforts or convenience are...

PA Court Agrees Injuries Were Compensable under Personal Comfort Doctrine PA Court Agrees Injuries Were Compensable under Personal Comfort Doctrine
Jan 14, 2022

The Case of the Missing Case

In early January, one can reliably count on at least two things: first, that we’ll be bombarded by television commercials hawking diet aids, and second, that someone in the New...

The Case of the Missing Case The Case of the Missing Case
Jan 13, 2022

Delaware High Court Says Sinkhole Injuries Were Not Compensable

The Supreme Court of Delaware affirmed the denial of workers’ compensation benefits to a courthouse employee who sustained injuries in a sinkhole accident near—but not on the courthouse property [Browning...

Delaware High Court Says Sinkhole Injuries Were Not Compensable Delaware High Court Says Sinkhole Injuries Were Not Compensable
Jan 13, 2022

Opinion Mondays: Is California’s “Posse Law” Passe?

In a case involving an utterly bizarre fact pattern, as well as a legal battle stretching out over the bulk of a decade, the Supreme Court of California, in a 5-2 decision, held that a civil action for negligence and misrepresentation filed by two private citizens against...

Opinion Mondays: Is California’s “Posse Law” Passe? Opinion Mondays: Is California’s “Posse Law” Passe?

New Comments

  • ramivou: They hid behind a flawed "reading" of this statute for a decade. I am glad the SC finally put an end to the misconception that it was a "first six months only" filing requirement, rather than an ongoing responsibility.
  • 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