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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 10, 2020

“Substantial” Evidence, Not Just “Some” Evidence Required to Rebut NY Presumption Regarding Unwitnessed Injuries

As is the rule in many jurisdictions [see Larson’s Workers’ Compensation Law, § 7.04], New York provides a presumption of compensability for accidents occurring during the course of employment which...

“Substantial” Evidence, Not Just “Some” Evidence Required to Rebut NY Presumption Regarding Unwitnessed Injuries “Substantial” Evidence, Not Just “Some” Evidence Required to Rebut NY Presumption Regarding Unwitnessed Injuries
Jan 9, 2020

The Top 10 Bizarre Workers’ Comp Cases for 2019

As I have noted many times on this blog site, more than 30 years ago my mentor, Dr. Arthur Larson, and I began a quirky—though humorous—New Year’s tradition. On an...

The Top 10 Bizarre Workers’ Comp Cases for 2019 The Top 10 Bizarre Workers’ Comp Cases for 2019
Dec 27, 2019

Idaho High Court Does “a 180”: Employees May Sue Employers for Reckless Conduct

Reversing itself (in relevant part), a divided Supreme Court of Idaho cast aside a year-old decision and, after re-argument, adopted what amounts to a reckless standard in so-called “intentional” tort...

Idaho High Court Does “a 180”: Employees May Sue Employers for Reckless Conduct Idaho High Court Does “a 180”: Employees May Sue Employers for Reckless Conduct
Dec 23, 2019

NY Court Bars IME Physician’s Testimony on Strict Procedural Grounds

A recent decision from the Empire State, Matter of Keller v. Cumberland Farms, 2019 N.Y. App. Div. LEXIS 9113 (3d Dept. Dec. 19, 2019), illustrates a point sometimes lost on...

NY Court Bars IME Physician’s Testimony on Strict Procedural Grounds NY Court Bars IME Physician’s Testimony on Strict Procedural Grounds
Dec 20, 2019

Divided Rhode Island Supreme Court Nixes Conclusive Cancer Presumptions for Firefighters

R.I. Gen. Laws § 45-19.1-1 (1956) does not create a conclusive presumption that cancer in firefighters arises out of and in the course of the employment, held a divided Supreme...

Divided Rhode Island Supreme Court Nixes Conclusive Cancer Presumptions for Firefighters Divided Rhode Island Supreme Court Nixes Conclusive Cancer Presumptions for Firefighters
Dec 19, 2019

Nevada Supreme Court Sets Out Rules Regarding Traveling Employees

In a case of first impression, the Supreme Court of Nevada addressed the traveling employee rule and, quoting Larson’s Workers’ Compensation Law, § 25.01, approved of the so-called Larson rule...

Nevada Supreme Court Sets Out Rules Regarding Traveling Employees Nevada Supreme Court Sets Out Rules Regarding Traveling Employees
Dec 17, 2019

Federal Court Says Action under Illinois Biometric Information Privacy Act is Not Barred by Exclusivity

In an interesting case that illustrates the tension between some of the recent technological “advances” that purportedly streamline traditional workplace practices, a federal district court yesterday held that a plaintiff’s...

Federal Court Says Action under Illinois Biometric Information Privacy Act is Not Barred by Exclusivity Federal Court Says Action under Illinois Biometric Information Privacy Act is Not Barred by Exclusivity
Dec 16, 2019

Proximity of NY Worker’s Termination to Claim Could Not Alone Establish Retaliatory Motive

Where a New York workers’ compensation claimant admitted that, prior to his work-related injury, he had been told by an employer’s representative that the employer had contacted the claimant’s union...

Proximity of NY Worker’s Termination to Claim Could Not Alone Establish Retaliatory Motive Proximity of NY Worker’s Termination to Claim Could Not Alone Establish Retaliatory Motive
Dec 13, 2019

State Court Strikes Down New York Board’s Eight-Page Brief Limitation

A regulation of New York’s Workers’ Compensation Board [N.Y. Comp. Codes R. & Regs., tit. 12, § 300.13(b)(1)(i)] that authorizes the Board to dismiss an application for Board review where...

State Court Strikes Down New York Board’s Eight-Page Brief Limitation State Court Strikes Down New York Board’s Eight-Page Brief Limitation
Dec 12, 2019

Divided Florida Court Says On-the-Clock Bowling Outing Was Not a Recreational Event

In a split decision, a Florida appellate court held that an employee’s injuries sustained while bowling with co-workers during an employer-sponsored event arose out of and in the course of...

Divided Florida Court Says On-the-Clock Bowling Outing Was Not a Recreational Event Divided Florida Court Says On-the-Clock Bowling Outing Was Not a Recreational Event
Dec 11, 2019

Nebraska Employer Need Not Pay for Unauthorized Medical Treatment in Florida Following Worker’s Relocation

Employer Balks at Out-of-State MD’s Recommendation of Long-Term Opioid Cocktail That an injured worker’s “Form 50” physician had died and the worker had subsequently moved from Nebraska to Florida did...

Nebraska Employer Need Not Pay for Unauthorized Medical Treatment in Florida Following Worker’s Relocation Nebraska Employer Need Not Pay for Unauthorized Medical Treatment in Florida Following Worker’s Relocation
Dec 10, 2019

Top 10 Workers’ Compensation Cases of 2019

At about this time each year, I highlight what I think are the ten most important workers’ compensation decisions reported during the calendar year. In some respects, 2019 has been...

Top 10 Workers’ Compensation Cases of 2019 Top 10 Workers’ Compensation Cases of 2019

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