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Jun 5, 2026

Iowa Supreme Court: Employer Not Bound by Opinion of Its Own Treating Physician

Many disputes over physician choice in workers’ compensation arise when an injured worker seeks treatment from a doctor of his or her own choosing. Hayes v. Christian Retirement Homes, Inc.,...

Iowa Supreme Court: Employer Not Bound by Opinion of Its Own Treating Physician Iowa Supreme Court: Employer Not Bound by Opinion of Its Own Treating Physician
Jun 2, 2026

Maine Supreme Court: Massachusetts Law Strips Staffing Client of Workers’ Compensation Immunity

Court Applies Massachusetts Law to Maine Injury, Rejects Immunity Defense in Multi-State Staffing Arrangement A New Hampshire contractor that likely would have enjoyed workers’ compensation immunity under Maine law lost...

Maine Supreme Court: Massachusetts Law Strips Staffing Client of Workers’ Compensation Immunity Maine Supreme Court: Massachusetts Law Strips Staffing Client of Workers’ Compensation Immunity
Jun 1, 2026

NY High Court Holds JIWA Bars Collateral Estoppel Effect of Pre-Enactment Workers’ Comp Decisions

New York’s Court of Appeals recently affirmed an Appellate Division order blocking defendants in a personal injury action from using a Workers’ Compensation Board causation determination as collateral estoppel, holding...

NY High Court Holds JIWA Bars Collateral Estoppel Effect of Pre-Enactment Workers’ Comp Decisions NY High Court Holds JIWA Bars Collateral Estoppel Effect of Pre-Enactment Workers’ Comp Decisions
May 27, 2026

Nebraska Supreme Court Affirms Denial of Death Benefits Where Work Injury Delayed Cancer Treatment

In a case involving a Nebraska truck driver-farm laborer whose treatment for metastatic cancer was allegedly postponed by complications associated with a compensable hip injury and its resulting treatment, the...

Nebraska Supreme Court Affirms Denial of Death Benefits Where Work Injury Delayed Cancer Treatment Nebraska Supreme Court Affirms Denial of Death Benefits Where Work Injury Delayed Cancer Treatment

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Dec 3, 2018

New York Court Says Attorney’s Ex Parte Text Message to Physician Was Harmless

In a divided decision, a New York appellate court recently held that the state’s Workers’ Compensation Board abused its discretion when it excluded from the record a physician’s medical report...

New York Court Says Attorney’s Ex Parte Text Message to Physician Was Harmless New York Court Says Attorney’s Ex Parte Text Message to Physician Was Harmless
Nov 29, 2018

2018’s Top 10 Workers’ Compensation Cases

In the Foreword of our forthcoming Workers’ Compensation Emerging Issues Analysis, 6th Edition [LexisNexis], due out in a few weeks, I note that in contrast to 2017, this year has...

2018’s Top 10 Workers’ Compensation Cases 2018’s Top 10 Workers’ Compensation Cases
Nov 27, 2018

Divided PA Supreme Court Refuses to Allow Comp Carrier to Maintain Third-Party Action on Behalf of Injured Employee

Injured Employee Must Either Assign Cause or Join Litigation as Party Plaintiff In Pennsylvania, a workers’ compensation insurance carrier may not maintain a third-party action against an alleged tortfeasor on...

Divided PA Supreme Court Refuses to Allow Comp Carrier to Maintain Third-Party Action on Behalf of Injured Employee Divided PA Supreme Court Refuses to Allow Comp Carrier to Maintain Third-Party Action on Behalf of Injured Employee
Nov 21, 2018

Massachusetts Retaliatory Discharge Statute Protects Employee’s Right to Sue Employer in Tort

A provision of the Massachusetts Workers’ Compensation Act (Act), Mass. Gen. Laws ch. 152, § 75B(2), and not the common law, affords an employee who was injured on the job...

Massachusetts Retaliatory Discharge Statute Protects Employee’s Right to Sue Employer in Tort Massachusetts Retaliatory Discharge Statute Protects Employee’s Right to Sue Employer in Tort
Nov 20, 2018

Idiopathic Fall to Level Floor May Be Compensable in Iowa

Divided Court Adopts Minority Rule for Idiopathic Falls Adopting the minority American rule that all work-related risk factors must be considered in determining the compensability of an idiopathic fall—even the...

Idiopathic Fall to Level Floor May Be Compensable in Iowa Idiopathic Fall to Level Floor May Be Compensable in Iowa
Nov 19, 2018

Massive Stroke After MMI Does Not Result in Loss of Nebraska PTD Benefits

Where an employee sustained work-related injuries, reached maximum medical improvement (MMI), and, based on factual findings by Nebraska’s Workers’ Compensation Court (WCC), was adjudged to be permanently and totally disabled,...

Massive Stroke After MMI Does Not Result in Loss of Nebraska PTD Benefits Massive Stroke After MMI Does Not Result in Loss of Nebraska PTD Benefits
Nov 19, 2018

NY’s Medical Treatment Guidelines Apply to Out-of-State Providers Treating Nonresident Claimants

In a decision that could have significant repercussions for a number of claimants under the New York Workers’ Compensation Law, a state appellate court affirmed a decision of the Workers’...

NY’s Medical Treatment Guidelines Apply to Out-of-State Providers Treating Nonresident Claimants NY’s Medical Treatment Guidelines Apply to Out-of-State Providers Treating Nonresident Claimants
Nov 16, 2018

Farm Worker’s Quick Visit to See Girlfriend and Get Beer Was Unreasonable Deviation From Employment

No Compensation Benefits for Injuries Sustained in Accident A farm worker, who sustained serious injuries in a vehicular accident when he failed to yield the right of way to oncoming...

Farm Worker’s Quick Visit to See Girlfriend and Get Beer Was Unreasonable Deviation From Employment Farm Worker’s Quick Visit to See Girlfriend and Get Beer Was Unreasonable Deviation From Employment
Nov 16, 2018

New York: Board—Not the Trial Court—Must Determine if Worker Was Independent Contractor

Reiterating the important rule in New York, that where the availability of workers’ compensation benefits hinges upon questions of fact or upon mixed questions of fact and law, the parties...

New York: Board—Not the Trial Court—Must Determine if Worker Was Independent Contractor New York: Board—Not the Trial Court—Must Determine if Worker Was Independent Contractor
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

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