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Mar 12, 2026

Virginia Court Counts Subcontractor Workers in Coverage Threshold Case

Small contractors sometimes believe that keeping their payroll lean — two employees instead of three — will keep them outside the reach of the workers’ compensation statute. But the Virginia...

Virginia Court Counts Subcontractor Workers in Coverage Threshold Case Virginia Court Counts Subcontractor Workers in Coverage Threshold Case
Mar 10, 2026

Second Circuit Bars Medical Marijuana Reimbursement Under the Longshore Act

In Garcia v. Director, Office of Workers’ Compensation Programs, 2026 U.S. App. LEXIS 6549 (2d Cir. Mar. 5, 2026), the Second Circuit denied a petition for review filed by a...

Second Circuit Bars Medical Marijuana Reimbursement Under the Longshore Act Second Circuit Bars Medical Marijuana Reimbursement Under the Longshore Act
Mar 6, 2026

New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits

Every dollar spent on workers’ compensation falls into one of two broad categories: benefits paid to injured workers—medical care and wage replacement—and the costs of delivering those benefits. The second...

New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits New York’s Hidden Cost Problem: WCRI Examines the Price of Delivering Benefits
Mar 5, 2026

Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage

In Motors v. Bayly (Red House Motors d/b/a Bayly’s Garage), 2026 Del. LEXIS 92 (Mar. 2, 2026), the Delaware Supreme Court reversed a Superior Court decision that the high court...

Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage Delaware Supreme Court Reinstates IAB’s Denial of Sole Proprietor Coverage

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Nov 15, 2018

The Quiet Before the Storm

Workers’ Compensation Emerging Issues Analysis, 2018 Edition For the past six years, I have been pleased to be a primary editor and contributing author of an annual publication, Workers’ Compensation...

The Quiet Before the Storm The Quiet Before the Storm
Nov 2, 2018

Ohio’s “Zone of Employment” Rule Protects Worker Who Clocked Out for Lunch

Injuries Sustained in Nearby Parking Lot Were Compensable Where an Ohio data entry worker had clocked out for lunch, exited the building, and fell in a nearby parking lot, breaking...

Ohio’s “Zone of Employment” Rule Protects Worker Who Clocked Out for Lunch Ohio’s “Zone of Employment” Rule Protects Worker Who Clocked Out for Lunch
Nov 2, 2018

Florida Court: No Coverage Where Policy Procured After Worker’s Injury Took Place

Agent Scurries to Get Coverage After Workplace Accident Where, following a workplace accident causing injury to an employee, the uninsured employer called its insurance broker regarding the expected workers’ compensation...

Florida Court: No Coverage Where Policy Procured After Worker’s Injury Took Place Florida Court: No Coverage Where Policy Procured After Worker’s Injury Took Place
Oct 30, 2018

Virginia Court Affirms Commission’s Safety Violation Finding

Driver’s Failure to Chock Wheels Results in Loss of Comp Benefits A Virginia appellate court recently affirmed a finding by the state’s Workers’ Compensation Commission that a truck driver willfully...

Virginia Court Affirms Commission’s Safety Violation Finding Virginia Court Affirms Commission’s Safety Violation Finding
Oct 26, 2018

Nebraska Physician Assistant May Not Sign Medical Report

While the term, “physician,” as defined by Neb. Workers’ Comp. R. 49(O) (2018), generally includes those practicing osteopathic medicine, chiropractic, podiatry, or dentistry, it does not include a physician assistant,...

Nebraska Physician Assistant May Not Sign Medical Report Nebraska Physician Assistant May Not Sign Medical Report
Oct 26, 2018

PA Governor Wolf Signs House Bill 1840 (i.e., “the Protz Fix”)

As was widely anticipated, on Wednesday (October 24, 2018), Pennsylvania Governor Tom Wolf signed House Bill 1840, known by some as “the Protz fix,” reestablishing that the AMA Guides, 6th...

PA Governor Wolf Signs House Bill 1840 (i.e., “the Protz Fix”) PA Governor Wolf Signs House Bill 1840 (i.e., “the Protz Fix”)
Oct 26, 2018

Trainee/Apprentice May Not Sue Independent Contractor/Truck Driver

Independent Contractor/Driver Was Joint Employer Under Iowa Law Construing Iowa law, the Eighth Circuit Court of Appeals recently affirmed a federal district court’s decision granting summary judgment to an independent...

Trainee/Apprentice May Not Sue Independent Contractor/Truck Driver Trainee/Apprentice May Not Sue Independent Contractor/Truck Driver
Oct 22, 2018

Protz “Fix” Awaits PA Governor’s Signature

Last Thursday (October 18, 2018), the Pennsylvania legislature sent House Bill 1840, a/k/a “the Protz Fix,” to Governor Wolf’s desk for his signature. Passed by an easy 34-15 margin, the...

Protz “Fix” Awaits PA Governor’s Signature Protz “Fix” Awaits PA Governor’s Signature
Oct 16, 2018

Vermont High Court Again Refuses to Utilize “Substantial Certainty” Exception for Intentional Injury Cases

Reiterating its decision in Kittell v. Vermont Weatherboard, Inc., 138 Vt. 439, 417 A.2d 926 (1980) (per curiam), in which the Supreme Court of Vermont held that nothing short of...

Vermont High Court Again Refuses to Utilize “Substantial Certainty” Exception for Intentional Injury Cases Vermont High Court Again Refuses to Utilize “Substantial Certainty” Exception for Intentional Injury Cases
Oct 15, 2018

Virginia Bus Driver’s Failure to Wear Seat Belt Constituted Willful Misconduct

A bus driver, who sustained serious injuries in an accident in which his bus was struck from behind, causing it to careen against a guard rail and then flip over,...

Virginia Bus Driver’s Failure to Wear Seat Belt Constituted Willful Misconduct Virginia Bus Driver’s Failure to Wear Seat Belt Constituted Willful Misconduct
Oct 15, 2018

Affiliated NY Company Liable for Half of Driver’s Comp Benefits as Special Employer

In Matter of Mitchell v. Eaton’s Trucking Serv., Inc., 2018 N.Y. App. Div. LEXIS 6806 (3rd Dept., Oct. 11, 2018), a New York appellate court affirmed a decision of the...

Affiliated NY Company Liable for Half of Driver’s Comp Benefits as Special Employer Affiliated NY Company Liable for Half of Driver’s Comp Benefits as Special Employer
Oct 9, 2018

Employee’s Medical Bills Not Covered by “Medpay” Provision of Arizona Auto Policy Due to Exclusion for Workers’ Compensation Benefits

Where an employee was injured in a work-related auto accident, incurred $22,000 in medical expenses, a portion of which was paid pursuant to a workers’ compensation claim and the employee...

Employee’s Medical Bills Not Covered by “Medpay” Provision of Arizona Auto Policy Due to Exclusion for Workers’ Compensation Benefits Employee’s Medical Bills Not Covered by “Medpay” Provision of Arizona Auto Policy Due to Exclusion for Workers’ Compensation Benefits

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