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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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Oct 4, 2021

Florida JCC Errs in Failing to Appoint EMA to Resolve Medical Dispute

Where a Florida workers’ compensation claimant disagreed with the medical opinion of the employer/carrier’s authorized physician, sought a one-time change in physicians pursuant to § 440.13(2)(f), Fla. Stat., saw a...

Florida JCC Errs in Failing to Appoint EMA to Resolve Medical Dispute Florida JCC Errs in Failing to Appoint EMA to Resolve Medical Dispute
Oct 1, 2021

Wisconsin Court Says UIM Carrier May Not Deduct Comp Benefits Subject to Subrogation Lien

A Wisconsin appellate court held that a deceased worker’s automobile insurance carrier, which had written a policy that included underinsured motorist’s (UIM) limits of $250,000, may only reduce its coverage...

Wisconsin Court Says UIM Carrier May Not Deduct Comp Benefits Subject to Subrogation Lien Wisconsin Court Says UIM Carrier May Not Deduct Comp Benefits Subject to Subrogation Lien
Sep 30, 2021

Ohio Claimant Disqualified from TTD Because She Gave Two-Week Notice Four Days Before Injury

An Ohio appellate court recently reversed a state Commission’s decision that had awarded TTD benefits to an employee who gave his employer a two-week notice that she intended to leave...

Ohio Claimant Disqualified from TTD Because She Gave Two-Week Notice Four Days Before Injury Ohio Claimant Disqualified from TTD Because She Gave Two-Week Notice Four Days Before Injury
Sep 28, 2021

Illinois Court Nixes Jurisdiction When Injury and Employment Contract Were in Indiana

In an unpublished decision, an Illinois appellate court reversed a decision of a county circuit court confirming an award of workers’ compensation benefits by the state’s Workers’ Compensation Commission on...

Illinois Court Nixes Jurisdiction When Injury and Employment Contract Were in Indiana Illinois Court Nixes Jurisdiction When Injury and Employment Contract Were in Indiana
Sep 27, 2021

South Dakota Court “Borrows” Going and Coming Rule for Negligence Action

The Supreme Court of South Dakota recently affirmed a trial court’s decision that granted summary judgment to a municipality and a volunteer fire department on the basis that the department’s...

South Dakota Court “Borrows” Going and Coming Rule for Negligence Action South Dakota Court “Borrows” Going and Coming Rule for Negligence Action
Sep 24, 2021

Iowa Court Affirms PPD Award Where Effects of Knee Injury Extended Beyond the Leg

Stressing that a claimant’s “injury” and “impairment” are not necessarily equivalents, an Iowa appellate court affirmed a determination that an injured worker was entitled to permanent partial disability benefits; he...

Iowa Court Affirms PPD Award Where Effects of Knee Injury Extended Beyond the Leg Iowa Court Affirms PPD Award Where Effects of Knee Injury Extended Beyond the Leg
Sep 22, 2021

Catch 22 Prevents Florida Officer From Utilizing Presumption of Compensability

A Florida appellate court affirmed a decision by a judge of compensation claims that found a law enforcement officer was not entitled to the special presumption of compensability related to...

Catch 22 Prevents Florida Officer From Utilizing Presumption of Compensability Catch 22 Prevents Florida Officer From Utilizing Presumption of Compensability
Sep 21, 2021

Florida Court Construes One-Time Change of Physician Statute

Where an injured employee sought a one-time change of physician and, within the five-day period designated in § 440.13(2)(f), Fla. Stat., was first given a referral physician and appointment options...

Florida Court Construes One-Time Change of Physician Statute Florida Court Construes One-Time Change of Physician Statute
Sep 20, 2021

NY Claimant’s Service Upon Third-Party Administrator Was Not Service Upon the Carrier Itself

While it is often said that the procedural aspects of a workers’ compensation dispute are largely informal, with the parties not always being bound to the narrowest interpretations of notice...

NY Claimant’s Service Upon Third-Party Administrator Was Not Service Upon the Carrier Itself NY Claimant’s Service Upon Third-Party Administrator Was Not Service Upon the Carrier Itself
Sep 16, 2021

NY Court Says Collateral Estoppel Bars Injured Worker’s Subsequent Negligence Action Against Defendants

A New York appellate court affirmed a decision by a state trial court that granted defendants summary judgment in a negligence action filed against them related to the alleged malfunction...

NY Court Says Collateral Estoppel Bars Injured Worker’s Subsequent Negligence Action Against Defendants NY Court Says Collateral Estoppel Bars Injured Worker’s Subsequent Negligence Action Against Defendants
Sep 14, 2021

Res Judicata Does Not Bar KY Employee From Reopening Claim

Quoting Larson’s Workers’ Compensation Law, and stressing that the doctrine of res judicata should be applied differently in workers’ compensation cases than in the usual context of a judicial action,...

Res Judicata Does Not Bar KY Employee From Reopening Claim Res Judicata Does Not Bar KY Employee From Reopening Claim
Sep 13, 2021

SC Commission is Immune From Suit After Apparent Stumbling With Attorney’s Fee Lien

A South Carolina appellate court affirmed a decision by a state trial court that dismissed the civil action filed against the S.C. Workers’ Compensation Commission by a law firm who...

SC Commission is Immune From Suit After Apparent Stumbling With Attorney’s Fee Lien SC Commission is Immune From Suit After Apparent Stumbling With Attorney’s Fee Lien

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