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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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Aug 10, 2015

Average Wage Calculation Must Be Computed For Nevada Self-Employed FedEx Driver

The lack of a salary associated with typical employment does not necessarily prevent an average monthly wage calculation for a self-employed injured Nevada worker, held the state’s Supreme Court last...

Average Wage Calculation Must Be Computed For Nevada Self-Employed FedEx Driver Average Wage Calculation Must Be Computed For Nevada Self-Employed FedEx Driver
Jul 22, 2015

Georgia Comp Board Won’t Resolve Fee Dispute Between Attorneys Dissolving Their Firm

In a dispute involving the dissolution of a law partnership and the rights of two attorneys in attorneys’ fees resulting from the settlement of workers’ compensation cases, Georgia’s Board of...

Georgia Comp Board Won’t Resolve Fee Dispute Between Attorneys Dissolving Their Firm Georgia Comp Board Won’t Resolve Fee Dispute Between Attorneys Dissolving Their Firm
Jul 16, 2015

Now California’s Pro Sports Cheerleaders are Employees

Anyone familiar with the FedEx, Uber/Lyft litigation going on at various levels in California’s courts and before the state’s administrative agencies knows that the Golden State appears to have “a...

Now California’s Pro Sports Cheerleaders are Employees Now California’s Pro Sports Cheerleaders are Employees
Jul 15, 2015

Assault by Nebraska Employee Against Sex Offender Co-Employee Did Not Arise from the Employment

Where an employee (“Bates”) assaulted a co-employee (“McDaniel”) after Bates performed an Internet search and discovered that McDaniel was a registered sex offender, the assault did not arise out of...

Assault by Nebraska Employee Against Sex Offender Co-Employee Did Not Arise from the Employment Assault by Nebraska Employee Against Sex Offender Co-Employee Did Not Arise from the Employment
Jul 7, 2015

NY Cage Dancer Forfeits Right to Future Comp Benefits

A New York appellate court has refused to vacate a portion of a county court’s judgment that, following a defendant’s guilty plea to fraudulent practices (N.Y. Workers’ Comp. Law §...

NY Cage Dancer Forfeits Right to Future Comp Benefits NY Cage Dancer Forfeits Right to Future Comp Benefits
Jul 3, 2015

How One State Bucked Trend of Allowing Former Spouse to Access Post-Divorce Workers’ Comp Benefits

With the divorce rate for U.S. marriages hovering at almost 50 percent, courts and legislatures are called upon to weigh two conflicting rules related to workers’ compensation benefits when it...

How One State Bucked Trend of Allowing Former Spouse to Access Post-Divorce Workers’ Comp Benefits How One State Bucked Trend of Allowing Former Spouse to Access Post-Divorce Workers’ Comp Benefits
Jun 25, 2015

New Mexico Court Finds State’s “Farm and Ranch Laborer” Exclusion Unconstitutional

In Rodriguez v. Brand West Dairy, 2015 N.M. App. LEXIS 69 (June 22, 2015), a divided Court of Appeals of New Mexico recently held that the exclusion of coverage afforded...

New Mexico Court Finds State’s “Farm and Ranch Laborer” Exclusion Unconstitutional New Mexico Court Finds State’s “Farm and Ranch Laborer” Exclusion Unconstitutional
Jun 24, 2015

Florida Appellate Court Throws Out Judge Cueto’s “Padgett” Decision on Procedural Grounds

Earlier today (June 24th), Florida’s Third District Court of Appeal reversed and completely repudiated the decision of Judge Jorge E. Cueto, Circuit Court for Miami-Dade County, that had, on August 19,...

Florida Appellate Court Throws Out Judge Cueto’s “Padgett” Decision on Procedural Grounds Florida Appellate Court Throws Out Judge Cueto’s “Padgett” Decision on Procedural Grounds
Jun 23, 2015

Maryland: Electronic Submission of Claim Does Not Toll Statute of Limitations

In Hranicka v. Chesapeake Surgical, Ltd., 2015 Md. LEXIS 413 (June 18, 2015), the Court of Appeals of Maryland held that an employee’s claim was time-barred under Md. Code Ann.,...

Maryland: Electronic Submission of Claim Does Not Toll Statute of Limitations Maryland: Electronic Submission of Claim Does Not Toll Statute of Limitations
Jun 15, 2015

Colorado High Court Ok’s Firing of Worker For State-Authorized Use of Medical Marijuana

Earlier today, the Supreme Court of Colorado, affirming a split decision of the state’s Court of Appeals, held that under the plain language of Colo. Rev. Stat. § 24–34–402.5, Colorado’s...

Colorado High Court Ok’s Firing of Worker For State-Authorized Use of Medical Marijuana Colorado High Court Ok’s Firing of Worker For State-Authorized Use of Medical Marijuana
Jun 12, 2015

Iowa Court Affirms Rejection of “Uncontradicted” Expert Testimony

An commissioner’s award of permanent total disability benefits to an HVAC employee who claimed he suffered an electric shock while servicing a unit at a customer’s residence was supported by...

Iowa Court Affirms Rejection of “Uncontradicted” Expert Testimony Iowa Court Affirms Rejection of “Uncontradicted” Expert Testimony
Jun 10, 2015

Ohio Worker Injured Having “Kick Ass Time” May Not Sue Co-Worker

An Ohio restaurant employee may not pursue a negligence action against a co-worker for personal injuries sustained in a golf cart accident that occurred on an island resort where the...

Ohio Worker Injured Having “Kick Ass Time” May Not Sue Co-Worker Ohio Worker Injured Having “Kick Ass Time” May Not Sue Co-Worker

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.