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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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Jan 28, 2020

Surreptitious Recording Reveals Firing Was Connected to Comp Claim and Not Immigration Status

Yesterday, a federal district court held that a Tennessee employer had violated state employment law regarding retaliatory discharge where the employee in question was fired within one hour of the...

Surreptitious Recording Reveals Firing Was Connected to Comp Claim and Not Immigration Status Surreptitious Recording Reveals Firing Was Connected to Comp Claim and Not Immigration Status
Jan 27, 2020

IL Supreme Court: Workers’ Compensation Settlement Proceeds Are Beyond Reach of Health Care Providers Who Treated the Worker

Last Friday, answering a question certified to it by the U.S. Court of Appeals for the Seventh Circuit, the Supreme Court of Illinois held that under section 21 of the...

IL Supreme Court: Workers’ Compensation Settlement Proceeds Are Beyond Reach of Health Care Providers Who Treated the Worker IL Supreme Court: Workers’ Compensation Settlement Proceeds Are Beyond Reach of Health Care Providers Who Treated the Worker
Jan 24, 2020

Arkansas Worker Fails to Show Injury Was Not “Substantially Occasioned” by Marijuana Use

Stressing that an Arkansas appellate court must defer to the state Commission’s findings of credibility and its resolution of conflicting evidence, even though it is the administrative law judge —...

Arkansas Worker Fails to Show Injury Was Not “Substantially Occasioned” by Marijuana Use Arkansas Worker Fails to Show Injury Was Not “Substantially Occasioned” by Marijuana Use
Jan 23, 2020

Blowing Both Hot and Cold: When Can Florida Employer Deny Comp Claim and Later Say Tort Action is Barred by Exclusive Remedy Rule?

Yesterday, a Florida appellate court held an employer and a co-employee were not estopped to raise the exclusive remedy defense in a civil action filed against them by a plaintiff...

Blowing Both Hot and Cold: When Can Florida Employer Deny Comp Claim and Later Say Tort Action is Barred by Exclusive Remedy Rule? Blowing Both Hot and Cold: When Can Florida Employer Deny Comp Claim and Later Say Tort Action is Barred by Exclusive Remedy Rule?
Jan 22, 2020

Firing Injured Florida Worker Before He Could File Claim Did Not Preclude Retaliatory Discharge Action

A Florida trial court erroneously granted a former employer summary judgment in a retaliatory discharge action filed by a former employee where the trial court based its decision on the...

Firing Injured Florida Worker Before He Could File Claim Did Not Preclude Retaliatory Discharge Action Firing Injured Florida Worker Before He Could File Claim Did Not Preclude Retaliatory Discharge Action
Jan 21, 2020

War Between the States: Federal Court Decides PA Law Precludes Third-Party Indemnity Action Against Employer

With a conflicting web of state versus state policies that would make any Conflict of Laws professor salivate, a federal district court in Pennsylvania found a choice of law provision...

War Between the States: Federal Court Decides PA Law Precludes Third-Party Indemnity Action Against Employer War Between the States: Federal Court Decides PA Law Precludes Third-Party Indemnity Action Against Employer
Jan 17, 2020

Divided Sixth Circuit Affirms Dismissal of Intentional Tort Action Filed against TN employer

In a split decision, the Sixth Circuit Court of Appeals affirmed the dismissal of an injured Tennessee worker’s intentional tort action against her employer based on the district court’s finding...

Divided Sixth Circuit Affirms Dismissal of Intentional Tort Action Filed against TN employer Divided Sixth Circuit Affirms Dismissal of Intentional Tort Action Filed against TN employer
Jan 16, 2020

Virginia Court Says Injuries Occurring Two Years Apart Can Actually Be From the “Same Accident”

Construing Va. Code Ann. § 65.2-503(C), which provides for PTD benefits, rather than PPD benefits, when an individual suffers the loss of use of two limbs in the same accident,...

Virginia Court Says Injuries Occurring Two Years Apart Can Actually Be From the “Same Accident” Virginia Court Says Injuries Occurring Two Years Apart Can Actually Be From the “Same Accident”
Jan 15, 2020

Iowa Claimant Allowed Alternate Treatment in Spite of Employer’s IME Request

In a proverbial “battle of the statutes,” an Iowa appellate court held that, under the facts of the case, a workers’ compensation decision granting a claimant’s application for alternate medical...

Iowa Claimant Allowed Alternate Treatment in Spite of Employer’s IME Request Iowa Claimant Allowed Alternate Treatment in Spite of Employer’s IME Request
Jan 13, 2020

NJ Court Approves Order Requiring Employer to Reimburse Worker for Medical Marijuana

In a case of first impression, earlier today (January 13, 2020), the Appellate Division of the Superior Court of New Jersey affirmed an order of a state workers’ compensation judge...

NJ Court Approves Order Requiring Employer to Reimburse Worker for Medical Marijuana NJ Court Approves Order Requiring Employer to Reimburse Worker for Medical Marijuana
Jan 13, 2020

NY Court Affirms Use of Hearsay Evidence to Establish Employee Fraud

In an unusual case that shows how traditional procedural rules can sometimes be disregarded in workers’ compensation cases, a New York appellate court affirmed a finding of the state’s Workers’...

NY Court Affirms Use of Hearsay Evidence to Establish Employee Fraud NY Court Affirms Use of Hearsay Evidence to Establish Employee Fraud
Jan 13, 2020

Opinion Mondays: Those Hiring Undocumented Workers Should Not be Allowed to Game the System

In a deeply divided (3-2) decision, a New York appellate court reversed a decision by the state's Workers' Compensation Compensation Board that had found an injured, undocumented construction worker had failed to establish, through a diligent, relevant search for employment, that he maintained the required connection to the labor market....

Opinion Mondays: Those Hiring Undocumented Workers Should Not be Allowed to Game the System Opinion Mondays: Those Hiring Undocumented Workers Should Not be Allowed to Game the System

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