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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 20, 2020

Divided MS Supreme Court Reverses Court of Appeals on Child Support Lien Issue

Reversing a decision by deeply divided Court of Appeals (for additional details on that earlier decision, see my post from last year), the Supreme Court of Mississippi, in a split...

Divided MS Supreme Court Reverses Court of Appeals on Child Support Lien Issue Divided MS Supreme Court Reverses Court of Appeals on Child Support Lien Issue
May 19, 2020

PA Commonwealth Court Says Protz Decision Was Not "Fully Retroactive"

In the continuing saga surrounding Pennsylvania’s Protz decision [see Protz v. Workers’ Compensation Appeal Board (Derry Area School District), 639 Pa. 645, 161 A.3d 827 (Pa. 2017)(Protz II)], the state’s...

PA Commonwealth Court Says Protz Decision Was Not "Fully Retroactive" PA Commonwealth Court Says Protz Decision Was Not "Fully Retroactive"
May 18, 2020

Opinion Mondays: Anachronistic Longings — the Co-Worker Lunch

As many of you know, as co-author of Larson’s Workers’ Compensation Law, I read — or truth be told, skim — many, many appellate decisions each year. Recently, because of...

Opinion Mondays: Anachronistic Longings — the Co-Worker Lunch Opinion Mondays: Anachronistic Longings — the Co-Worker Lunch
May 14, 2020

NC Commission Erred in Dismissing Claim With Prejudice

Noting that dismissal with prejudice is the most severe sanction available to the court in a civil case, and thus, it should not be readily granted, a North Carolina appellate...

NC Commission Erred in Dismissing Claim With Prejudice NC Commission Erred in Dismissing Claim With Prejudice
May 13, 2020

Virginia High Court Says Permanent Impairment Computed Before, Not After, Hip Replacement Surgery

In a decision that is likely to raise some eyebrows, a divided Supreme Court of Virginia, affirming an earlier decision by a lower appellate court, held that an injured employee’s...

Virginia High Court Says Permanent Impairment Computed Before, Not After, Hip Replacement Surgery Virginia High Court Says Permanent Impairment Computed Before, Not After, Hip Replacement Surgery
May 12, 2020

NY Carrier Fails to Notify its Attorney of Claimant’s Application for Board Review and Loses Appeal

Illustrating what can happen when a workers' compensation carrier fails to notify its counsel of the carrier's receipt of important papers concerning a claim, a New York appellate court affirmed...

NY Carrier Fails to Notify its Attorney of Claimant’s Application for Board Review and Loses Appeal NY Carrier Fails to Notify its Attorney of Claimant’s Application for Board Review and Loses Appeal
May 11, 2020

Opinion Mondays: While We’re Adjusting Our COVID-19 Masks, Is the Grand Bargain Being Altered?

In a document published in February, the Congressional Research Service observed: “Workers’ compensation has been called a grand bargain between employers and workers … [under which] workers receive guaranteed, no-fault...

Opinion Mondays: While We’re Adjusting Our COVID-19 Masks, Is the Grand Bargain Being Altered? Opinion Mondays: While We’re Adjusting Our COVID-19 Masks, Is the Grand Bargain Being Altered?
May 8, 2020

Florida Employee Awarded PTD Benefits 17 Years After Retirement

In a case in which the original work-related injury occurred two decades before the appellate decision, a Florida appellate court held that a JCC erred in focusing on a claimant's...

Florida Employee Awarded PTD Benefits 17 Years After Retirement Florida Employee Awarded PTD Benefits 17 Years After Retirement
May 7, 2020

Injured VA Employee May Not Merely Accept Lowest-Paying Post-Injury Job and Recover Difference in Earnings

A Virginia appellate court recently affirmed a decision by the state's Workers' Compensation Commission that denied temporary partial disability benefits to an injured employee under Va. Code Ann. § 65.2-502,...

Injured VA Employee May Not Merely Accept Lowest-Paying Post-Injury Job and Recover Difference in Earnings Injured VA Employee May Not Merely Accept Lowest-Paying Post-Injury Job and Recover Difference in Earnings
May 5, 2020

New York's "Gray Area" Rule Does Not Aid Claimant Struck by Car Near Workplace

A New York appellate court affirmed a finding by the state’s Workers’ Compensation Board that a claimant/employee did not sustain injuries arising out of and in the course of his...

New York's "Gray Area" Rule Does Not Aid Claimant Struck by Car Near Workplace New York's "Gray Area" Rule Does Not Aid Claimant Struck by Car Near Workplace
May 4, 2020

Opinion Mondays: Old Influenza Case From Hawaii Shows How COVID-19 Presumptions Might Work

In recent weeks, as multiple states have established presumptions of compensability favoring some workers who contract the coronavirus/COVID-19, many within the workers’ compensation community have pondered just how these presumptions...

Opinion Mondays: Old Influenza Case From Hawaii Shows How COVID-19 Presumptions Might Work Opinion Mondays: Old Influenza Case From Hawaii Shows How COVID-19 Presumptions Might Work
May 1, 2020

Florida Court Says Cardiac Presumption Favoring Corrections Officer Was Rebutted

In a case that provides guidance for employers and carriers who seek to rebut the special presumption of compensability provided to firefighters and certain other “covered officers” (including corrections officers)...

Florida Court Says Cardiac Presumption Favoring Corrections Officer Was Rebutted Florida Court Says Cardiac Presumption Favoring Corrections Officer Was Rebutted

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