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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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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
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

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