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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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Apr 30, 2020

Washington Landscaper Denied Benefits After "Blowing" Twice the Legal Limit

In a decision not designated for publication, an appellate court from the state of Washington affirmed a jury’s determination that an injured worker was intoxicated to such an extent that...

Washington Landscaper Denied Benefits After "Blowing" Twice the Legal Limit Washington Landscaper Denied Benefits After "Blowing" Twice the Legal Limit
Apr 29, 2020

PA Commonwealth Court Reverses ALJ's Decision Awarding Unreasonable Contest Fees

In a decision that discusses the complex give and take between an injured Pennsylvania employee and an employer who contends that the employee no longer is entitled to a payment...

PA Commonwealth Court Reverses ALJ's Decision Awarding Unreasonable Contest Fees PA Commonwealth Court Reverses ALJ's Decision Awarding Unreasonable Contest Fees
Apr 28, 2020

Federal District Court Says Proximity of Firing to Filing Claim Was Alone Insufficient to Survive Employer’s Motion for Summary Judgment

Construing Colorado law, a federal district court granted, in relevant part, a former employer’s motion for summary judgment in a case filed against it for retaliatory discharge [Donez v. Leprino...

Federal District Court Says Proximity of Firing to Filing Claim Was Alone Insufficient to Survive Employer’s Motion for Summary Judgment Federal District Court Says Proximity of Firing to Filing Claim Was Alone Insufficient to Survive Employer’s Motion for Summary Judgment
Apr 27, 2020

Opinion Mondays: Later Today, IL Comm'n Will Say "Ooops" as to its Presumption of Compensability

Governor and Legislators Might Profit From Reading PA’s Protz Decision The controversial “rule change” put in place two weeks ago by the Illinois Workers’ Compensation Commission, which purports to create...

Opinion Mondays: Later Today, IL Comm'n Will Say "Ooops" as to its Presumption of Compensability Opinion Mondays: Later Today, IL Comm'n Will Say "Ooops" as to its Presumption of Compensability
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

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