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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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Mar 5, 2020

SC Supreme Court Says Deceased Worker’s “Girlfriend” Failed to Show Dependency

Reversing a decision of the state’s Court of Appeals, and side-stepping — at least to some degree — the issue of illicit relationships, the Supreme Court of South Carolina found...

SC Supreme Court Says Deceased Worker’s “Girlfriend” Failed to Show Dependency SC Supreme Court Says Deceased Worker’s “Girlfriend” Failed to Show Dependency
Mar 3, 2020

Virginia Police Officer’s Knowledge of Special Heart-Lung Presumption Does Not Trigger Statute of Limitations

Where a Virginia police officer in 2009 and 2010 signed acknowledgments that he had received a copy of Virginia’s special heart-lung presumption favoring police officers and certain others, the state’s...

Virginia Police Officer’s Knowledge of Special Heart-Lung Presumption Does Not Trigger Statute of Limitations Virginia Police Officer’s Knowledge of Special Heart-Lung Presumption Does Not Trigger Statute of Limitations
Mar 2, 2020

NY Court Disapproves of Board’s “Virtual Banking” of Benefits Where Claimant Returns to Work at Preinjury Wages

Where a law judge found that an injured New York worker was entitled to a PPD classification based on impairments to her cervical and lumbar spine, entitling her to nonschedule...

NY Court Disapproves of Board’s “Virtual Banking” of Benefits Where Claimant Returns to Work at Preinjury Wages NY Court Disapproves of Board’s “Virtual Banking” of Benefits Where Claimant Returns to Work at Preinjury Wages
Feb 28, 2020

Uninsured NY Employer May Not Use “Grave Injury” Statute to Defend 3rd-Party Indemnity Claim

In relevant part, N.Y. Workers’ Comp. Law § 11 prohibits third-party claims for indemnification and contribution against an employer unless the injured employee has sustained a “grave injury” as defined...

Uninsured NY Employer May Not Use “Grave Injury” Statute to Defend 3rd-Party Indemnity Claim Uninsured NY Employer May Not Use “Grave Injury” Statute to Defend 3rd-Party Indemnity Claim
Feb 27, 2020

Michigan Auditor’s Auto Accident Injury Claim Not Barred by Going and Coming Rule

Stressing that the Michigan Supreme Court’s Stark decision had not set forth four “factors” to be weighed in determining whether a claimant’s going and coming injury nevertheless occurred in the...

Michigan Auditor’s Auto Accident Injury Claim Not Barred by Going and Coming Rule Michigan Auditor’s Auto Accident Injury Claim Not Barred by Going and Coming Rule
Feb 26, 2020

NY Hospital Employee’s Tort Action Against Outside Management Services Company Barred by Exclusive Remedy Doctrine

Where a hospital entered into a contract with a management services company (“the management company”), pursuant to which the management company trained and sometimes supervised the hospital’s “housekeepers,” but where...

NY Hospital Employee’s Tort Action Against Outside Management Services Company Barred by Exclusive Remedy Doctrine NY Hospital Employee’s Tort Action Against Outside Management Services Company Barred by Exclusive Remedy Doctrine
Feb 24, 2020

Missouri Claimants Not Entitled to Statutory “Enhanced Benefit” for Worker’s Mesothelioma

In Missouri, where employers have elected to accept mesothelioma liability pursuant to a special provision of the state Act — Mo. Rev. Stat. § 287.200.4(3)(a)(2013) — the employer becomes liable...

Missouri Claimants Not Entitled to Statutory “Enhanced Benefit” for Worker’s Mesothelioma Missouri Claimants Not Entitled to Statutory “Enhanced Benefit” for Worker’s Mesothelioma
Feb 21, 2020

Arkansas Worker Fails to Rebut Presumption After Positive Drug Test

An Arkansas appellate court affirmed a decision by the state’s Workers’ Compensation Commission that held an injured worker had failed to rebut the presumption that his work-related injury was “substantially...

Arkansas Worker Fails to Rebut Presumption After Positive Drug Test Arkansas Worker Fails to Rebut Presumption After Positive Drug Test
Feb 20, 2020

Georgia Employee Not Entitled to Change in Physician Since Injury Was Resolved

Where the Georgia Board found that the employee’s work-related injuries had resolved prior to the date the employee requested a change in her treating physician, it was appropriate for the...

Georgia Employee Not Entitled to Change in Physician Since Injury Was Resolved Georgia Employee Not Entitled to Change in Physician Since Injury Was Resolved
Feb 19, 2020

Unusual “Event” Versus Unusual “Stress”: AZ Court Says Commission Should Reconsider Deputy Sheriff’s PTSD Claim

Construing Ariz. Rev. Stat. § 23-1043.01(B), which denies coverage for mental injuries, such as PTSD, unless some “unexpected, unusual or extraordinary stress related to the employment … was a substantial...

Unusual “Event” Versus Unusual “Stress”: AZ Court Says Commission Should Reconsider Deputy Sheriff’s PTSD Claim Unusual “Event” Versus Unusual “Stress”: AZ Court Says Commission Should Reconsider Deputy Sheriff’s PTSD Claim
Feb 18, 2020

Around the Horn: Admissibility of Hearsay in Workers’ Compensation Cases

It is axiomatic that the procedural law of workers’ compensation takes its lead and tone from the beneficent nature of the legislation. Except in those few jurisdictions utilizing court administration...

Around the Horn: Admissibility of Hearsay in Workers’ Compensation Cases Around the Horn: Admissibility of Hearsay in Workers’ Compensation Cases
Feb 17, 2020

Utah Worker Found to Have Sustained PTD In Spite of His Return to Work

Acknowledging that in most cases in Utah, an injured worker who is capable of returning to work full-time cannot be considered to have sustained permanent total disability, a state appellate...

Utah Worker Found to Have Sustained PTD In Spite of His Return to Work Utah Worker Found to Have Sustained PTD In Spite of His Return to Work

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