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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 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
Apr 7, 2020

In Georgia, Borrowed Servant is Co-Employee of Borrowing Employer’s “Regular” Employee

In Georgia, a borrowed servant is, even though temporarily, the co-employee of the borrowing employer’s regular employees. Accordingly, such a borrowed servant may not sue one of the employer’s regular...

In Georgia, Borrowed Servant is Co-Employee of Borrowing Employer’s “Regular” Employee In Georgia, Borrowed Servant is Co-Employee of Borrowing Employer’s “Regular” Employee
Apr 6, 2020

Opinion Mondays: “Old” Case Law May Be Key to Many Coronavirus Claims

Over the past several weeks, as the coronavirus pandemic has raged across the United States, several state governors and a number of state legislatures have announced, and in a few...

Opinion Mondays: “Old” Case Law May Be Key to Many Coronavirus Claims Opinion Mondays: “Old” Case Law May Be Key to Many Coronavirus Claims
Apr 2, 2020

Virginia School Guard’s Injuries Allegedly Caused by Wind Were Not Compensable

Applying Virginia’s so-called “actual risk test,” a state appellate court affirmed a decision by the Virginia Workers’ Compensation Commission that had denied benefits to a school security officer who fell...

Virginia School Guard’s Injuries Allegedly Caused by Wind Were Not Compensable Virginia School Guard’s Injuries Allegedly Caused by Wind Were Not Compensable
Mar 31, 2020

Arkansas Carrier Wins: Requires Premiums Be Paid on Worker’s Earnings, Then Says He Was Independent Contractor

In a real “head-scratcher,” an Arkansas appellate court, relying on a 50-year-old decision of the state’s Supreme Court, held that the Arkansas Commission did not err when it determined that...

Arkansas Carrier Wins: Requires Premiums Be Paid on Worker’s Earnings, Then Says He Was Independent Contractor Arkansas Carrier Wins: Requires Premiums Be Paid on Worker’s Earnings, Then Says He Was Independent Contractor
Mar 30, 2020

New Feature: Opinion Mondays — In the COVID-19 Medical Crisis, Who Is on the Front Line?

Last Wednesday (March 25), North Dakota Governor Doug Burgum signed Executive Order 2020-12 that, as of March 13, 2020, purports to extend special worker compensation protections to first responders, health...

New Feature: Opinion Mondays — In the COVID-19 Medical Crisis, Who Is on the Front Line? New Feature: Opinion Mondays — In the COVID-19 Medical Crisis, Who Is on the Front Line?
Mar 27, 2020

SC Supreme Court Stresses Commission May Not Use Credibility as a Wild Card

Acknowledging that when South Carolina’s Workers’ Compensation Commission makes a credibility determination based on substantial evidence, that credibility finding itself is substantial evidence, and factual findings properly based on such...

SC Supreme Court Stresses Commission May Not Use Credibility as a Wild Card SC Supreme Court Stresses Commission May Not Use Credibility as a Wild Card
Mar 26, 2020

$2.9 Million California Judgment Against Employer Stands in Muddled Green Card Application Case

A California appellate court affirmed a $2.9 million judgment entered against a former movie industry employer who botched the green card application process of one of its foreign employees, resulting...

$2.9 Million California Judgment Against Employer Stands in Muddled Green Card Application Case $2.9 Million California Judgment Against Employer Stands in Muddled Green Card Application Case
Mar 25, 2020

SD Supreme Court Construes State’s “No Progress” Rule in Comp Cases

Construing South Dakota’s “no progress” rule [S.D. Admin. R. 47:03:01:09], which allows the state’s Department of Labor to dismiss a workers’ compensation petition when there has been “no activity for...

SD Supreme Court Construes State’s “No Progress” Rule in Comp Cases SD Supreme Court Construes State’s “No Progress” Rule in Comp Cases

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