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Jan 6, 2025

Iowa Court Affirms Denial of Benefits re: COVID-19 Claim

In Collins v. Des Moines Area Regional Transit Authority (DART), 2024 Iowa App. LEXIS 918 (Dec. 18, 2024), the Iowa Court of Appeals affirmed denial of workers’ compensation benefits to...

Iowa Court Affirms Denial of Benefits re: COVID-19 Claim Iowa Court Affirms Denial of Benefits re: COVID-19 Claim
Jan 6, 2025

Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence

In Spisa-Kline v. Mary Lanning Memorial Hospital, 2024 Neb. App. LEXIS 750 (Dec. 31, 2024), the Nebraska Court of Appeals affirmed summary judgment for the employer in a workers’ compensation...

Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence Nebraska COVID-19 Claim Fails For Want of Expert Medical Evidence
Dec 31, 2024

Oregon Jaywalker Might Be Awarded Benefits

Appeals Court Examines Going and Coming Rule The Oregon Court of Appeals has reversed and remanded a Workers’ Compensation Board decision that had denied benefits to a worker injured while...

Oregon Jaywalker Might Be Awarded Benefits Oregon Jaywalker Might Be Awarded Benefits
Dec 30, 2024

NC Court of Appeals Reverses $28.9 Million Tort Judgment

Insurer Had No Duty to Defend Intentional Tort Claim Against Co-Employee In Ortez v. Penn Nat’l Sec. Ins. Co., 2024 N.C. App. LEXIS 1017 (Dec. 17, 2024), the North Carolina...

NC Court of Appeals Reverses $28.9 Million Tort Judgment NC Court of Appeals Reverses $28.9 Million Tort Judgment

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Oct 13, 2015

New York Nurse Awarded 90% Loss of Wage-Earning Capacity Due to Allergic Reaction to Hand Sanitizer

A New York appellate court affirmed a finding by the state’s Workers’ Compensation Board that a former critical care nurse suffered a work-related 90 percent loss of wage-earning capacity where...

New York Nurse Awarded 90% Loss of Wage-Earning Capacity Due to Allergic Reaction to Hand Sanitizer New York Nurse Awarded 90% Loss of Wage-Earning Capacity Due to Allergic Reaction to Hand Sanitizer
Oct 12, 2015

Wyoming Employer Need Not Keep Immigration Documentation on Hand

While the workers’ compensation laws of virtually all states include illegally employed persons—e.g., minors and undocumented “aliens”—within the term “employee,” Wyoming’s definition is more restrictive. Only those aliens whom the...

Wyoming Employer Need Not Keep Immigration Documentation on Hand Wyoming Employer Need Not Keep Immigration Documentation on Hand
Sep 28, 2015

Wyoming High Court Adopts “Substantial and Motivating Factor” Test to Judge Retaliatory Discharge Claim

Adopting the “substantial and motivating factor” test to determine if an employer’s decision to terminate a worker’s employment was retaliatory, the Supreme Court of Wyoming reversed a trial court order...

Wyoming High Court Adopts “Substantial and Motivating Factor” Test to Judge Retaliatory Discharge Claim Wyoming High Court Adopts “Substantial and Motivating Factor” Test to Judge Retaliatory Discharge Claim
Sep 22, 2015

PA Court Strikes Down Use of AMA Guides, 6th Ed.

Last Friday, a deeply divided Commonwealth Court of Pennsylvania struck down as unconstitutional the requirement, codified in § 306(a.2) of the state’s Workers’ Compensation Act [77 Pa. Stat. Ann. §...

PA Court Strikes Down Use of AMA Guides, 6th Ed. PA Court Strikes Down Use of AMA Guides, 6th Ed.
Sep 11, 2015

Ohio Court Again Says TTD Benefits Unaffected by Pre-Injury Drug Use Undetected Until After Injury

An Ohio appellate court has again concluded that the doctrine of voluntary abandonment does not bar an injured worker’s entitlement to TTD compensation in a case involving a pre-injury infraction—here,...

Ohio Court Again Says TTD Benefits Unaffected by Pre-Injury Drug Use Undetected Until After Injury Ohio Court Again Says TTD Benefits Unaffected by Pre-Injury Drug Use Undetected Until After Injury
Sep 2, 2015

Washington High Court Says Valley Fever is Not Covered by Firefighters’ Presumption

Valley fever is not a “respiratory disease” for purposes of the state of Washington’s firefighters presumption [Wash. Rev. Code § 51.21.185(1)]; it is instead an “infectious disease” and is not...

Washington High Court Says Valley Fever is Not Covered by Firefighters’ Presumption Washington High Court Says Valley Fever is Not Covered by Firefighters’ Presumption
Aug 28, 2015

Kentucky High Court Says “Concurrent” Wages May Only Be Considered for AWW Computation if Concurrent Employment Existed on DOI

Where an injured employee had but one employer on the date of injury, the employee’s average weekly wage must be computed by considering only the wages from that employer; “concurrent”...

Kentucky High Court Says “Concurrent” Wages May Only Be Considered for AWW Computation if Concurrent Employment Existed on DOI Kentucky High Court Says “Concurrent” Wages May Only Be Considered for AWW Computation if Concurrent Employment Existed on DOI
Aug 27, 2015

Tennessee Mattress Store Manager Prevails in PTSD Claim After Encounter with Purse Snatching Customers

The manager of a Tennessee mattress store, who alleged that she sustained a psychological injury (“PTSD”) when she pursued two persons into the employer’s store parking lot after they had...

Tennessee Mattress Store Manager Prevails in PTSD Claim After Encounter with Purse Snatching Customers Tennessee Mattress Store Manager Prevails in PTSD Claim After Encounter with Purse Snatching Customers
Aug 26, 2015

NC Employee’s Injury Playing Laser Tag Found Compensable

An employee who suffered a knee injury while playing laser tag at a company-sponsored marketing conference sustained an accidental injury arising out of and in the course of the employment,...

NC Employee’s Injury Playing Laser Tag Found Compensable NC Employee’s Injury Playing Laser Tag Found Compensable
Aug 19, 2015

Illinois Welder’s Knee Injury While Swiveling in Chair Found Compensable

Using a neutral risk analysis, an Illinois appellate court reversed a trial court’s decision that in turn had affirmed the denial of workers’ compensation benefits to a worker who injured...

Illinois Welder’s Knee Injury While Swiveling in Chair Found Compensable Illinois Welder’s Knee Injury While Swiveling in Chair Found Compensable
Aug 12, 2015

NC: Surviving Spouse Loses Claim for Death Benefits Since She Neither Lived With Nor Was Dependent Upon Worker at Time of His Death

A surviving spouse was not entitled to receive workers’ compensation death benefits where evidence established that she left the family home several years prior to the deceased employee’s death, rarely...

NC: Surviving Spouse Loses Claim for Death Benefits Since She Neither Lived With Nor Was Dependent Upon Worker at Time of His Death NC: Surviving Spouse Loses Claim for Death Benefits Since She Neither Lived With Nor Was Dependent Upon Worker at Time of His Death
Aug 11, 2015

Under DC Comp Act, Emailing Order to Employer Does Not Start 10-Day Period for Payment Without Penalty

Virtually all workers’ compensation acts impose a penalty for late payment of benefits. For example, D.C. Code § 32–1515(f) provides for a 20 percent penalty if any compensation is not...

Under DC Comp Act, Emailing Order to Employer Does Not Start 10-Day Period for Payment Without Penalty Under DC Comp Act, Emailing Order to Employer Does Not Start 10-Day Period for Payment Without Penalty

New Comments

  • 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
  • Thomas A. Robinson: Good point, although the interesting thing about the case--at least to me--is that it discusses the important "injury by accident" issue. That issue, present in at least a plurality of state acts, is largely ignored by Commissions, Boards, and Courts these days. Here, also, the case was so fact-specific that even it had been issued as published, it would be factually distinguishable from many othe...
  • kathlyn gorman: It should have been noted in your discussion that this is an unpublished opinion of the North Carolina Court of Appeals. Thus, it does not constitute controlling legal authority.
  • Thomas A. Robinson: You're correct. Ordinarily, I can depend upon Alabama to provide me with at least one case for "the List." I'll bet 2022 will unearth something bizarre from the Great State of Alabama. Take care.