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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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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
May 19, 2021

Staffing Company’s Should Not Conflate Employment Contract and Specific Assignment

Employment Contract Formed In Illinois In Spite of Contingencies Required for First Assignment in Indiana In an unpublished decision, an Illinois appellate court affirmed a decision by the state’s Workers’...

Staffing Company’s Should Not Conflate Employment Contract and Specific Assignment Staffing Company’s Should Not Conflate Employment Contract and Specific Assignment
May 17, 2021

NY Court Says Law Judge Must Limit Decision to Actual Issue at Hand

Illustrating the important point that a hearing officer or judge must stick to those matters that are specifically at issue, and not wander off to determine other questions that might...

NY Court Says Law Judge Must Limit Decision to Actual Issue at Hand NY Court Says Law Judge Must Limit Decision to Actual Issue at Hand
May 13, 2021

PA Tow Truck Operator Was Employee, Not an Independent Contractor

In Berkebile Towing & Recovery v. Workers’ Comp. Appeal Bd. (Harr), 2021 Pa. Commw. LEXIS 427 (May 10, 2021), the Commonwealth Court of Pennsylvania affirmed a decision by the state’s...

PA Tow Truck Operator Was Employee, Not an Independent Contractor PA Tow Truck Operator Was Employee, Not an Independent Contractor
May 11, 2021

Arizona Employee’s Idiopathic Fall is Not Compensable

In an unpublished decision, an Arizona appellate court affirmed a determination by the state’s Industrial Commission that found an employee’s workers’ compensation claim was not compensable because the employee’s injuries...

Arizona Employee’s Idiopathic Fall is Not Compensable Arizona Employee’s Idiopathic Fall is Not Compensable
May 10, 2021

KY Supreme Court Construes Agricultural Employee Exemption

The Supreme Court of Kentucky, construing the state’s agricultural employee exemption [see Ky. Rev. Stat. Ann. §§ 342.650(5) and 342.0011(18)], reversed a split decision of the state’s Court of Appeals...

KY Supreme Court Construes Agricultural Employee Exemption KY Supreme Court Construes Agricultural Employee Exemption
May 4, 2021

NY Claimant Should Not Have Been Permanently Barred From Indemnity Benefits

A New York appellate court held that while the state’s Workers’ Compensation Board was within its discretion when it found an injured worker had violated N.Y. Workers’ Comp. Law §...

NY Claimant Should Not Have Been Permanently Barred From Indemnity Benefits NY Claimant Should Not Have Been Permanently Barred From Indemnity Benefits
May 3, 2021

Split 9th Circuit Panel Overturns Injunction Favoring Golden State Truckers

Panel Says District Court Abused Discretion Last Wednesday, in California Trucking Ass’n v. Bonta, 2021 U.S. App. LEXIS 12629 (9th Cir., Apr. 28, 2021), a divided panel of the Ninth...

Split 9th Circuit Panel Overturns Injunction Favoring Golden State Truckers Split 9th Circuit Panel Overturns Injunction Favoring Golden State Truckers
Apr 29, 2021

Federal Court Allows Comp Insurer to Intervene in Injured Worker’s Third-Party Action

Providing a casebook-like discussion of the issues related to a workers’ compensation insurer’s intervention in a third-party civil action, the U.S. District Court for the Eastern District of Missouri held...

Federal Court Allows Comp Insurer to Intervene in Injured Worker’s Third-Party Action Federal Court Allows Comp Insurer to Intervene in Injured Worker’s Third-Party Action

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