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Mar 10, 2026

Second Circuit Bars Medical Marijuana Reimbursement Under the Longshore Act

In Garcia v. Director, Office of Workers’ Compensation Programs, 2026 U.S. App. LEXIS 6549 (2d Cir. Mar. 5, 2026), the Second Circuit denied a petition for review filed by a...

Second Circuit Bars Medical Marijuana Reimbursement Under the Longshore Act Second Circuit Bars Medical Marijuana Reimbursement Under the Longshore Act
Mar 6, 2026

New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits

Every dollar spent on workers’ compensation falls into one of two broad categories: benefits paid to injured workers—medical care and wage replacement—and the costs of delivering those benefits. The second...

New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits
Mar 5, 2026

Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage

In Motors v. Bayly (Red House Motors d/b/a Bayly’s Garage), 2026 Del. LEXIS 92 (Mar. 2, 2026), the Delaware Supreme Court reversed a Superior Court decision that the high court...

Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage
Mar 3, 2026

Florida Court Invalidates Rules Expanding “Absolute Choice” Pharmacy Provision

In Publix Super Markets, Inc. v. Department of Financial Services, 2026 Fla. App. LEXIS 1469 (Fla. 1st DCA Feb. 25, 2026), the First District Court of Appeal recently held that...

Florida Court Invalidates Rules Expanding “Absolute Choice” Pharmacy Provision Florida Court Invalidates Rules Expanding “Absolute Choice” Pharmacy Provision

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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
May 24, 2021

Employee’s Action Against Employer’s Comp Insurer For Self-Inflicted Gunshot Wound Barred by Exclusivity

In a divided decision, the Supreme Court of Wisconsin affirmed a finding by the state’s Court of Appeals that the exclusive remedy provisions of the Wisconsin Workers’ Compensation Act barred...

Employee’s Action Against Employer’s Comp Insurer For Self-Inflicted Gunshot Wound Barred by Exclusivity Employee’s Action Against Employer’s Comp Insurer For Self-Inflicted Gunshot Wound Barred by Exclusivity

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