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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
Jul 8, 2026

KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths

Supervisors Who Allegedly Blocked Exits Fell Outside the Workers’ Comp Act’s Exclusive Remedy The Kentucky Court of Appeals has revived tort claims brought by survivors of the December 2021 tornado...

KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths KY Court Revives Tort Claims From Mayfield Candle Factory Tornado Deaths

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Sep 18, 2019

West Virginia: No Dependency Established Where Daughter Had not Lived With Employee for 25 Years

In a memorandum decision that illustrates one of the several important distinctions between the tort law world, which tends to emphasize property rights (converting, if you will, even pain and...

West Virginia: No Dependency Established Where Daughter Had not Lived With Employee for 25 Years West Virginia: No Dependency Established Where Daughter Had not Lived With Employee for 25 Years
Sep 17, 2019

Colorado Employer’s First Report of Injury and Other Preliminary Filings Do Not Toll Statute of Limitations

In Colorado, the statute of limitations applicable to the state’s Workers’ Compensation Act [Colo. Rev. Stat. § 8-43-103(2)] is not tolled by the filing of the employer’s first report of...

Colorado Employer’s First Report of Injury and Other Preliminary Filings Do Not Toll Statute of Limitations Colorado Employer’s First Report of Injury and Other Preliminary Filings Do Not Toll Statute of Limitations
Sep 16, 2019

NY Court: “Attachment to Labor Market” Amendment Not Always Applied Retroactively

The 2017 amendment to N.Y. Workers’ Comp. Law § 15(3)(w), which relieves some permanently partially disabled claimants of the obligation to show labor market attachment, does not apply retroactively in all...

NY Court: “Attachment to Labor Market” Amendment Not Always Applied Retroactively NY Court: “Attachment to Labor Market” Amendment Not Always Applied Retroactively
Sep 13, 2019

Michigan Commission May Not Establish Overpayment Rules Re: Workers’ Comp Benefits on its Own

Where the Michigan Legislature had promulgated one right of reimbursement for overpayment of workers’ compensation benefits—allowing recovery of the overpayment made within one year of the recoupment action under MCL...

Michigan Commission May Not Establish Overpayment Rules Re: Workers’ Comp Benefits on its Own Michigan Commission May Not Establish Overpayment Rules Re: Workers’ Comp Benefits on its Own
Sep 12, 2019

Wyoming High Court Says Both Employer and Division of Workers’ Compensation Estopped From Using Statute of Limitations Defense

In a complex case, with procedural twists and turns, the Supreme Court of Wyoming reversed a finding that an employee’s claim for workers’ compensation benefits was barred because he failed...

Wyoming High Court Says Both Employer and Division of Workers’ Compensation Estopped From Using Statute of Limitations Defense Wyoming High Court Says Both Employer and Division of Workers’ Compensation Estopped From Using Statute of Limitations Defense
Sep 11, 2019

Utah High Court Comes Close to Adopting Positional Risk for Unexplained Falls

The Supreme Court of Utah affirmed a finding by the state’s Labor Commission that an employee’s injuries sustained in an unexplained fall in a parking lot adjacent to the employer’s...

Utah High Court Comes Close to Adopting Positional Risk for Unexplained Falls Utah High Court Comes Close to Adopting Positional Risk for Unexplained Falls
Sep 10, 2019

Sixth Circuit Side-Steps Federal Immigration Issue in Retaliatory Discharge Action

While hypothetical questions may have been the standard in law school courses taught via the Socratic Method, the Sixth Circuit recently held such questions are not to be considered by...

Sixth Circuit Side-Steps Federal Immigration Issue in Retaliatory Discharge Action Sixth Circuit Side-Steps Federal Immigration Issue in Retaliatory Discharge Action
Sep 6, 2019

Tourist Medicine May Be Coming to a Comp Claim Near You

A Funny Thing Happened on the Way to the Doctor. I shared a nostalgic conversation last week with a similarly-aged J.D. about our early days of law practice. More than...

Tourist Medicine May Be Coming to a Comp Claim Near You Tourist Medicine May Be Coming to a Comp Claim Near You
Sep 5, 2019

Provision of Vehicle to Employee Not Controlling Factor in Texas Death Benefits Case

The provision by an employer of a company-owned vehicle was insufficient to establish a work-connection between an employee’s fatal vehicle accident and the employment, held a Texas appellate court recently...

Provision of Vehicle to Employee Not Controlling Factor in Texas Death Benefits Case Provision of Vehicle to Employee Not Controlling Factor in Texas Death Benefits Case
Aug 30, 2019

Rule 12(b)(1) vs. 12(b)(6): What’s the Difference? Parties Discover that With Motions to Dismiss, Subsections Matter

Questions of employer immunity from actions for workplace injuries do not raise issues pertaining to the original subject matter jurisdiction of Washington's superior courts, held a state appellate court in...

Rule 12(b)(1) vs. 12(b)(6): What’s the Difference? Parties Discover that With Motions to Dismiss, Subsections Matter Rule 12(b)(1) vs. 12(b)(6): What’s the Difference? Parties Discover that With Motions to Dismiss, Subsections Matter
Aug 29, 2019

Texas Gross Negligence Statute Requires Showing of Both Objective and Subjective Elements

Construing Tex. Lab. Code Ann. § 408.001(b), which provides that the exclusive remedy provision of the Texas Workers’ Compensation Act does not prohibit the recovery of exemplary damages by the...

Texas Gross Negligence Statute Requires Showing of Both Objective and Subjective Elements Texas Gross Negligence Statute Requires Showing of Both Objective and Subjective Elements
Aug 27, 2019

Maryland First Responder’s Degenerative Knee Condition is Occupational “Disease”

In a divided decision, the Court of Appeals of Maryland yesterday held that since there was no showing that a first responder had a concomitant preexisting condition, and since he...

Maryland First Responder’s Degenerative Knee Condition is Occupational “Disease” Maryland First Responder’s Degenerative Knee Condition is Occupational “Disease”

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