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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 19, 2014

Annual Service Bonus is Part of Iowa Employee’s Average Weekly Wage Computation

Where the only conditions precedent to receiving an annual bonus was simply being an “active employee on November 30th of the year the bonus was paid and the condition precedent...

Annual Service Bonus is Part of Iowa Employee’s Average Weekly Wage Computation Annual Service Bonus is Part of Iowa Employee’s Average Weekly Wage Computation
Aug 15, 2014

Louisiana Claimant Gets Hit With Forfeiture of Benefits and Stiff Penalties for Misrepresentations

A Louisiana appellate court has affirmed an Order of the state’s Office of Workers’ Compensation that heavily sanctioned a workers’ compensation claimant for fraud in violation of La. R. S....

Louisiana Claimant Gets Hit With Forfeiture of Benefits and Stiff Penalties for Misrepresentations Louisiana Claimant Gets Hit With Forfeiture of Benefits and Stiff Penalties for Misrepresentations
Aug 8, 2014

Nebraska High Court Clarifies “Manifestation” Date in Repetitive Trauma Cases

The Supreme Court of Nebraska recently held that for purposes of assigning liability among several employers for a dental hygienist’s repetitive trauma injury, the injury manifested itself on the day...

Nebraska High Court Clarifies “Manifestation” Date in Repetitive Trauma Cases Nebraska High Court Clarifies “Manifestation” Date in Repetitive Trauma Cases
Aug 5, 2014

Divided California Supreme Court Says In-Home Caregivers May Not Sue Alzheimer’s Patients For Injuries

Acknowledging that agitation and physical aggression are common late-stage symptoms of Alzheimer’s disease, that injuries to caregivers are not unusual, and that California and other jurisdictions had previously established the...

Divided California Supreme Court Says In-Home Caregivers May Not Sue Alzheimer’s Patients For Injuries Divided California Supreme Court Says In-Home Caregivers May Not Sue Alzheimer’s Patients For Injuries
Jul 28, 2014

Alaska: Same-Sex Partner of Deceased Worker Entitled to Death Benefits In Spite of State’s “Marriage Amendment”

On Friday, the Supreme Court of Alaska, in Harris v. Millennium Hotel, 2014 Alas. LEXIS 149 (July 25, 2014), held that the state’s workers’ compensation death benefits statute, Alaska Stat....

Alaska: Same-Sex Partner of Deceased Worker Entitled to Death Benefits In Spite of State’s “Marriage Amendment” Alaska: Same-Sex Partner of Deceased Worker Entitled to Death Benefits In Spite of State’s “Marriage Amendment”
Jul 25, 2014

Pennsylvania: Claimant’s Invocation of Self-Incrimination Rights Cannot, Standing Alone, Furnish Sufficient Evidence to Suspend Comp Benefits

On Monday, in Cruz v. Workers’ Comp. Appeal Bd. (Kennett Square Specialties), 2014 Pa. LEXIS 1772 (July 21, 2014), the Supreme Court of Pennsylvania held that as to the proper...

Pennsylvania: Claimant’s Invocation of Self-Incrimination Rights Cannot, Standing Alone, Furnish Sufficient Evidence to Suspend Comp Benefits Pennsylvania: Claimant’s Invocation of Self-Incrimination Rights Cannot, Standing Alone, Furnish Sufficient Evidence to Suspend Comp Benefits
Jul 16, 2014

Illinois Court Says “Ordinary” Reaching Activity is Nevertheless Risk of Employment

Acknowledging that there are three categories of risk to which an employee may be exposed: (1) risks distinctly associated with her employment; (2) personal risks; and (3) neutral risks which...

Illinois Court Says “Ordinary” Reaching Activity is Nevertheless Risk of Employment Illinois Court Says “Ordinary” Reaching Activity is Nevertheless Risk of Employment
Jul 7, 2014

New York Court Affirms PTSD Award to Physician’s Assistant Threatened by Surgeon During Surgical Procedure

A New York appellate court has affirmed a decision of the state’s Workers’ Compensation Board that awarded workers compensation benefits for a stress-related injury sustained by a cardiothoracic physician’s assistant...

New York Court Affirms PTSD Award to Physician’s Assistant Threatened by Surgeon During Surgical Procedure New York Court Affirms PTSD Award to Physician’s Assistant Threatened by Surgeon During Surgical Procedure
Jul 1, 2014

Ohio: Trouble-Maker Fails to Prove Discharge Was Because of Workers’ Compensation Claims

Acknowledging that two employees who had been embroiled in a shouting match during the work day had been treated different by the employer–the employee who apparently started the argument received...

Ohio: Trouble-Maker Fails to Prove Discharge Was Because of Workers’ Compensation Claims Ohio: Trouble-Maker Fails to Prove Discharge Was Because of Workers’ Compensation Claims
Jun 30, 2014

Illinois: Tort Action Against Employer Not Barred Where Workers’ Comp Claim Was Time-Barred Before Employee Ever Learned of It

In a case of first impression, an Illinois appellate court, reversing a decision by a state trial court, has ruled that neither the exclusive remedy provisions of the Illinois Workers’...

Illinois: Tort Action Against Employer Not Barred Where Workers’ Comp Claim Was Time-Barred Before Employee Ever Learned of It Illinois: Tort Action Against Employer Not Barred Where Workers’ Comp Claim Was Time-Barred Before Employee Ever Learned of It
Jun 26, 2014

Oooops! In Ruling on Collateral Estoppel Issue, What Does a Court Do if Its Earlier Decision Was Actually Wrong?

In what is likely the last few days of the current term of the United States Supreme Court, an army of prognosticators are looking up from their tea leaves into...

Oooops! In Ruling on Collateral Estoppel Issue, What Does a Court Do if Its Earlier Decision Was Actually Wrong? Oooops! In Ruling on Collateral Estoppel Issue, What Does a Court Do if Its Earlier Decision Was Actually Wrong?
Jun 9, 2014

Florida Court Says PTSD Patient’s Ability to Communicate Directly With Psychologist is Not “Medical Necessity”

What if an injured worker was legally prevented from discussing his or her medical condition directly with the worker’s doctor, if the worker was required instead to listen to the...

Florida Court Says PTSD Patient’s Ability to Communicate Directly With Psychologist is Not “Medical Necessity” Florida Court Says PTSD Patient’s Ability to Communicate Directly With Psychologist is Not “Medical Necessity”

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.