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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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Mar 21, 2014

Virginia Court Requires Insurer to Provide Transportation to Doctor’s Office In Spite of Fact That It Already Paid to Modify Vehicle

It is one thing to modify an injured employee’s vehicle so as to accommodate his wheelchair or scooter. It is quite another to provide the employee with necessary transportation assistance...

Virginia Court Requires Insurer to Provide Transportation to Doctor’s Office In Spite of Fact That It Already Paid to Modify Vehicle Virginia Court Requires Insurer to Provide Transportation to Doctor’s Office In Spite of Fact That It Already Paid to Modify Vehicle
Mar 13, 2014

PA Court Refuses to Consider Independent, Board-Certified MD’s Opinion Because of Her Practice “Mix”

When is the opinion of a board-certified (occupational medicine) physician, with years of experience and special training in the utilization of the AMA Guides, and who has performed numerous Impairment...

PA Court Refuses to Consider Independent, Board-Certified MD’s Opinion Because of Her Practice “Mix” PA Court Refuses to Consider Independent, Board-Certified MD’s Opinion Because of Her Practice “Mix”
Mar 10, 2014

Minnesota High Court Says PTSD is No “Brain Injury”

Reiterating the Minnesota rule that so-called “mental-mental” injuries–mental injuries associated with mental stimulus, as opposed to physical stimulus–are not compensable and that it is for the state’s legislature, and not...

Minnesota High Court Says PTSD is No “Brain Injury” Minnesota High Court Says PTSD is No “Brain Injury”
Mar 7, 2014

Benign Neglect: Can Failure to Follow Doctor’s Advice Be Fatal to Injured Worker’s Claim?

Within the workers’ compensation arena, it is axiomatic that the medical consequences and sequelae that flow from the primary injury are themselves compensable. [see Larson’s Workers’ Compensation Law, § 10.01]....

Benign Neglect: Can Failure to Follow Doctor’s Advice Be Fatal to Injured Worker’s Claim? Benign Neglect: Can Failure to Follow Doctor’s Advice Be Fatal to Injured Worker’s Claim?
Feb 27, 2014

Compromise and Settlement: May An Employer Include a Penalty Clause to Ward Off Further Vexatious Claims?

Each year I read–or at least scan–more than 1,500 workers’ compensation cases that make the appellate reporter system around the nation. As large as that number sounds, it’s really fewer...

Compromise and Settlement: May An Employer Include a Penalty Clause to Ward Off Further Vexatious Claims? Compromise and Settlement: May An Employer Include a Penalty Clause to Ward Off Further Vexatious Claims?
Feb 25, 2014

Ohio: Comatose Injured Worker’s Additional Claim for Loss of Vision and Hearing Fails

The Supreme Court of Ohio, reversing an earlier decision by an intermediate appellate court, recently affirmed the state Industrial Commission’s denial of a loss of vision and hearing claim under...

Ohio: Comatose Injured Worker’s Additional Claim for Loss of Vision and Hearing Fails Ohio: Comatose Injured Worker’s Additional Claim for Loss of Vision and Hearing Fails
Feb 25, 2014

Bariatric Surgery: Is it a Workers’ Compensation Medical Benefit?

Last week, I was very pleased to be a part of an Orlando, Florida risk management conference sponsored by Artex Risk Solutions. Along with two good friends and colleagues, Rebecca...

Bariatric Surgery: Is it a Workers’ Compensation Medical Benefit? Bariatric Surgery: Is it a Workers’ Compensation Medical Benefit?
Feb 17, 2014

Louisiana: Mileage Payment Does Not Bring EMT’s Travel Within the Employment; Going and Coming Rule Bars Claim

In Potier v. Acadian Ambulance Serv., Inc., 2014 La. App. LEXIS 347 (February 12, 2014), a Louisiana appellate court recently affirmed a decision by a state workers’ compensation judge that...

Louisiana: Mileage Payment Does Not Bring EMT’s Travel Within the Employment; Going and Coming Rule Bars Claim Louisiana: Mileage Payment Does Not Bring EMT’s Travel Within the Employment; Going and Coming Rule Bars Claim
Feb 17, 2014

NY: Employer Does Not Lose Exclusivity Defense in Contribution/Indemnification Case Because Employee was Undocumented Alien

N.Y. Work. Comp. Law § 11 bars third-party lawsuits for contribution and indemnification against an injured employee’s employer unless either (a) the employee suffered a “grave injury,” limited to death...

NY: Employer Does Not Lose Exclusivity Defense in Contribution/Indemnification Case Because Employee was Undocumented Alien NY: Employer Does Not Lose Exclusivity Defense in Contribution/Indemnification Case Because Employee was Undocumented Alien
Feb 14, 2014

NY Court: No Reopening Allowed in Established Claim re: Murdered Employee

Indicating that in New York there were two requisites for reopening a claim based on newly acquired evidence: (a) the application to reopen “must be made within a reasonable time...

NY Court: No Reopening Allowed in Established Claim re: Murdered Employee NY Court: No Reopening Allowed in Established Claim re: Murdered Employee
Feb 13, 2014

Idaho Shoe Lace Causes Compensable Herniated Disc

In a decision showing just how strongly the state’s workers’ compensation system separates the “arising out of” the employment component of the compensation formula from the “course of employment” component,...

Idaho Shoe Lace Causes Compensable Herniated Disc Idaho Shoe Lace Causes Compensable Herniated Disc
Feb 11, 2014

Texas Exclusive Remedy Provision Does Not Apply to Health Care Providers

The exclusive remedy provision of Tex. Lab. Code Ann. § 408.001(a) does not apply to health care providers, held a Texas appellate court recently, in Hand & Wrist Center of...

Texas Exclusive Remedy Provision Does Not Apply to Health Care Providers Texas Exclusive Remedy Provision Does Not Apply to Health Care Providers

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.