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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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Apr 24, 2020

NY Employer/Carrier May Preclude Medical Reports Without Enforcing Subpoenas

Yesterday, a New York appellate court held that the Board's decision to preclude medical reports of two of claimant's treating physicians was appropriate in spite of the fact that the...

NY Employer/Carrier May Preclude Medical Reports Without Enforcing Subpoenas NY Employer/Carrier May Preclude Medical Reports Without Enforcing Subpoenas
Apr 23, 2020

NY Claimant's False Representations Lead to Disqualification from Future Benefits

A New York appellate court affirmed a determination by a state Workers’ Compensation Law Judge, later upheld by New York’s Board, that disqualified a claimant from receiving future wage replacement...

NY Claimant's False Representations Lead to Disqualification from Future Benefits NY Claimant's False Representations Lead to Disqualification from Future Benefits
Apr 22, 2020

Idaho Court Says Bodies of Tandem Skydivers Are Not "Equipment"

Acknowledging that one of the important factors to be considered in determining whether a worker is an independent contractor, rather than an employee, is whether the worker brings important “equipment”...

Idaho Court Says Bodies of Tandem Skydivers Are Not "Equipment" Idaho Court Says Bodies of Tandem Skydivers Are Not "Equipment"
Apr 21, 2020

NY Court Construes State’s Traveling Employee Rules and Affirms Award of Benefits

Construing the state’s traveling employee rules, as those rules pertain to claims for workers’ compensation benefits, a New York appellate court affirmed a decision by the state’s Workers’ Compensation Board...

NY Court Construes State’s Traveling Employee Rules and Affirms Award of Benefits NY Court Construes State’s Traveling Employee Rules and Affirms Award of Benefits
Apr 20, 2020

Opinion Mondays: "The First Shall Be First, and the Last Shall Remain Last"

COVID-19 Legislation Continues to Follow Discriminatory Practices The workers’ compensation coronavirus legislation recently passed in Wisconsin and Utah continues to follow the predictable pattern of discriminating against many who face...

Opinion Mondays: "The First Shall Be First, and the Last Shall Remain Last" Opinion Mondays: "The First Shall Be First, and the Last Shall Remain Last"
Apr 17, 2020

Injured NY Worker Who Received Comp Benefits Might Also Recover in Tort Against Co-Worker

In an unusual case with an interesting twist, a New York appellate court yesterday affirmed a decision by a state trial court that denied a defendant's motion for summary judgment...

Injured NY Worker Who Received Comp Benefits Might Also Recover in Tort Against Co-Worker Injured NY Worker Who Received Comp Benefits Might Also Recover in Tort Against Co-Worker
Apr 16, 2020

"First Do No Harm" – Missouri Employee's Injuries At Doctor's Office Not Compensable

The Supreme Court of Missouri, construing the state’s special causation rules for workers’ compensation claims, affirmed a decision by the state’s Labor and Industrial Relations Commission that denied an employee’s...

"First Do No Harm" – Missouri Employee's Injuries At Doctor's Office Not Compensable "First Do No Harm" – Missouri Employee's Injuries At Doctor's Office Not Compensable
Apr 15, 2020

For NY Board's Form RB-89, Question 15's "When" Did Not Mean a Specific Date

New York practitioners are aware that when a party seeks review of a WCLJ's findings, the state's Workers' Compensation Board has become quite strict in its examination of a party's...

For NY Board's Form RB-89, Question 15's "When" Did Not Mean a Specific Date For NY Board's Form RB-89, Question 15's "When" Did Not Mean a Specific Date
Apr 13, 2020

In Illinois, You Need Neither a Legislature Nor a Governor: Comp Commission Unilaterally Changes its Rules of Evidence

In this morning’s post, I was critical of a number of states whose governors had marched to the microphone and camera and, in the face of the COVID-19 pandemic, announced...

In Illinois, You Need Neither a Legislature Nor a Governor: Comp Commission Unilaterally Changes its Rules of Evidence In Illinois, You Need Neither a Legislature Nor a Governor: Comp Commission Unilaterally Changes its Rules of Evidence
Apr 13, 2020

Opinion Mondays: State Governors Have Pens, Who Needs Legislatures?

Since the outbreak of the coronavirus pandemic, a number of state governors (e.g., California, Kentucky, Missouri, and North Dakota) have issued executive orders promising extended workers’ compensation benefits and, in...

Opinion Mondays: State Governors Have Pens, Who Needs Legislatures? Opinion Mondays: State Governors Have Pens, Who Needs Legislatures?
Apr 10, 2020

Broken Ankle Results in Permanent Total Disability for Nebraska Truck Driver

Illustrating yet again, that the age-old adage that an employer generally takes an employee as it finds him or her, a Nebraska appellate court affirmed a finding by the state’s...

Broken Ankle Results in Permanent Total Disability for Nebraska Truck Driver Broken Ankle Results in Permanent Total Disability for Nebraska Truck Driver
Apr 9, 2020

NC Court Narrows State’s Traveling Employee Rule

In a decision that could have important implications for those who travel as part of their work for North Carolina employers, a state appellate court, affirming a decision of the...

NC Court Narrows State’s Traveling Employee Rule NC Court Narrows State’s Traveling Employee Rule

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