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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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Dec 26, 2018

Immunity Afforded to Ohio Subcontractors Under Contractor’s Self-Insurance Plan is Constitutional

The grant of immunity afforded to subcontractors enrolled in an Ohio contractor’s self-insurance plan [see Ohio Rev. Code Ann. § 4123.35(O)] from claims by employees of another enrolled subcontractor does...

Immunity Afforded to Ohio Subcontractors Under Contractor’s Self-Insurance Plan is Constitutional Immunity Afforded to Ohio Subcontractors Under Contractor’s Self-Insurance Plan is Constitutional
Dec 20, 2018

Deeply Divided Oklahoma High Court Says Reduction of PPD Allowed Where Employer Paid Full Wages During Police Officer’s Disability Period

In a deeply divided (5-4) decision, the Supreme Court of Oklahoma recently held that a provision in the state’s workers’ compensation law [Okla. Stat. tit. 85A, § 89] allowing an...

Deeply Divided Oklahoma High Court Says Reduction of PPD Allowed Where Employer Paid Full Wages During Police Officer’s Disability Period Deeply Divided Oklahoma High Court Says Reduction of PPD Allowed Where Employer Paid Full Wages During Police Officer’s Disability Period
Dec 11, 2018

South Carolina: In Dependency Case, Commission May Not Presume “Fornication” Occurred

In an ancient decision (one year older than me), Day v. Day, 216 S.C. 334, 58 S.E.2d 83 (1950), the Supreme Court of South Carolina, reflecting the general moral mindset...

South Carolina: In Dependency Case, Commission May Not Presume “Fornication” Occurred South Carolina: In Dependency Case, Commission May Not Presume “Fornication” Occurred
Dec 10, 2018

Nevada Employer Need Not Show Knowledge of Specific Medical Diagnosis to Recover from Subsequent Injury Fund

In Nevada, under Nev. Rev. Stat. § 616B.578, in order for an employer to receive reimbursement from the state’s “Subsequent Injury Account,” it must prove that that it had knowledge...

Nevada Employer Need Not Show Knowledge of Specific Medical Diagnosis to Recover from Subsequent Injury Fund Nevada Employer Need Not Show Knowledge of Specific Medical Diagnosis to Recover from Subsequent Injury Fund
Dec 10, 2018

29-Month Delay in Filing North Dakota Claim Bars Recovery

The Supreme Court of North Dakota recently affirmed an ALJ’s finding that the filing of a worker’s claim some 29 months after the work incident was not timely, and, therefore,...

29-Month Delay in Filing North Dakota Claim Bars Recovery 29-Month Delay in Filing North Dakota Claim Bars Recovery
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

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