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Apr 21, 2025

MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases

In a thoughtful and clarifying opinion, the Minnesota Supreme Court has reaffirmed the case-specific nature of the statutory retirement presumption applicable to permanent total disability (PTD) claims under Minn. Stat....

MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases MN High Court Reaffirms Case-Specific Standard in PTD Retirement Presumption Cases
Apr 17, 2025

Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951)

Introduction In 1951, the U.S. Supreme Court handed down its decision in O’Leary v. Brown-Pacific-Maxon, Inc., 340 U.S. 504, 71 S.Ct. 470, 95 L.Ed.483 (1951). The case involved a claim...

Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951) Throwback Thursday: O’Leary v. Brown-Pacific-Maxon, Inc. (U.S., 1951)
Apr 15, 2025

Arkansas Court Denies Benefits to Good Samaritan Band Director

In a ruling that reaffirms Arkansas’ strict interpretation of its “employment services” requirement, the state’s Court of Appeals recently affirmed a Workers’ Compensation Commission decision denying benefits to the family...

Arkansas Court Denies Benefits to Good Samaritan Band Director Arkansas Court Denies Benefits to Good Samaritan Band Director
Apr 14, 2025

Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack

In a decision that further defines the barriers to pursuing civil remedies in workplace injury cases within the Louisiana, a state appellant court recently affirmed summary a trial court judgment...

Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack Louisiana Court Rejects “Borrowed Employee” Theory in Workplace Attack

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Nov 28, 2014

NY: Co-employee Immunity Bars Exercise Rider’s Suit For Crushed Foot From Falling Anvil

A civil action filed by one equestrian exercise rider against another for injuries sustained when an anvil owned by the defendant fell from defendant’s vehicle and crushed plaintiff’s foot is...

NY: Co-employee Immunity Bars Exercise Rider’s Suit For Crushed Foot From Falling Anvil NY: Co-employee Immunity Bars Exercise Rider’s Suit For Crushed Foot From Falling Anvil
Nov 19, 2014

Illinois Widow Gets Death Benefits after Husband Succumbs to Neisseria Meningitides Contracted on Brazilian Business Trip

In a decision that may provide some indication as to how the court might decide a claim involving Ebola exposure, an Illinois appellate court has affirmed a finding by the...

Illinois Widow Gets Death Benefits after Husband Succumbs to Neisseria Meningitides Contracted on Brazilian Business Trip Illinois Widow Gets Death Benefits after Husband Succumbs to Neisseria Meningitides Contracted on Brazilian Business Trip
Nov 18, 2014

Delaware Employer’s Inability to Rehire Undocumented Worker Following Injury is Its Worry, Not the Worker’s

Observing that the employee must must be taken as he or she was hired, that in determining an employee’s “earning power” following an injury, Delaware courts are authorized to consider...

Delaware Employer’s Inability to Rehire Undocumented Worker Following Injury is Its Worry, Not the Worker’s Delaware Employer’s Inability to Rehire Undocumented Worker Following Injury is Its Worry, Not the Worker’s
Nov 11, 2014

“Dog Bites Man”: Pennsylvania Court Affirms Award for Worker Bitten By Co-Worker’s Canine

Yesterday, a Pennsylvania appellate court affirmed an order by the state’s Workers’ Compensation Appeal Board awarding workers’ compensation benefits to a worker who sustained facial lacerations and permanent scarring when...

“Dog Bites Man”: Pennsylvania Court Affirms Award for Worker Bitten By Co-Worker’s Canine “Dog Bites Man”: Pennsylvania Court Affirms Award for Worker Bitten By Co-Worker’s Canine
Nov 6, 2014

Pennsylvania Ex-Husband’s LHWCA Benefits Subject to Attachment by Former Spouse for Unpaid Alimony

Longshore and Harbor Workers’ Compensation Act disability benefits are subject to attachment by a worker’s former spouse, held a Pennsylvania court yesterday in Uveges v. Uveges, 2014 PA Super 251, 2014...

Pennsylvania Ex-Husband’s LHWCA Benefits Subject to Attachment by Former Spouse for Unpaid Alimony Pennsylvania Ex-Husband’s LHWCA Benefits Subject to Attachment by Former Spouse for Unpaid Alimony
Nov 4, 2014

Iowa: Surveillance Videos of Injured Workers Not Protected by Work Product Privilege

A divided Court of Appeals of Iowa, in Iowa Insurance Institute v. Core Group of the Iowa Association for Justice, 2014 Iowa App. LEXIS 1067 (Oct. 29, 2014), has held...

Iowa: Surveillance Videos of Injured Workers Not Protected by Work Product Privilege Iowa: Surveillance Videos of Injured Workers Not Protected by Work Product Privilege
Oct 25, 2014

Arkansas: The Second You’re Off the Clock, You’re On Your Own

Construing A.C.A. § 11–9–102(4)(B)(iii), which provides in relevant part that a compensable injury does not include any injury inflicted upon the employee at a time when employment services were not...

Arkansas: The Second You’re Off the Clock, You’re On Your Own Arkansas: The Second You’re Off the Clock, You’re On Your Own
Oct 17, 2014

Commentary: Ebola Has Everybody Spooked; They’re Even Calling Me With Questions

Ebola has everyone spooked. I read this afternoon that a Dallas health care worker who handled one or more lab specimens from the Liberian man who died from Ebola is...

Commentary: Ebola Has Everybody Spooked; They’re Even Calling Me With Questions Commentary: Ebola Has Everybody Spooked; They’re Even Calling Me With Questions
Oct 10, 2014

Commentary: For Whom Are You Working? Ohio Court Creates Twilight Zone For Temporary Workers

Disruption Caused by Growth in Number of Temporary/Contingent Workers A few days ago, my close colleague, Robin Kobayashi, and I put the final touches on a new book, Workers’ Compensation...

Commentary: For Whom Are You Working? Ohio Court Creates Twilight Zone For Temporary Workers Commentary: For Whom Are You Working? Ohio Court Creates Twilight Zone For Temporary Workers
Sep 29, 2014

Wyoming Court Says Undocumented Worker Might Be Able to Employ Ingenious Argument to Avoid Exclusive Remedy Defense

The Wyoming Supreme Court, construing the statutory provision within the state’s Workers’ Compensation Act (“the Act”) defining “employee,” recently held that an an undocumented worker might be able to take...

Wyoming Court Says Undocumented Worker Might Be Able to Employ Ingenious Argument to Avoid Exclusive Remedy Defense Wyoming Court Says Undocumented Worker Might Be Able to Employ Ingenious Argument to Avoid Exclusive Remedy Defense
Sep 24, 2014

Oregon Home Health Care Worker’s Employment Is Broader Than Approved Task List

Like a number of other states, Oregon has a program through which its Department of Human Services provides home health care services to qualifying clients (state citizens), at state expense....

Oregon Home Health Care Worker’s Employment Is Broader Than Approved Task List Oregon Home Health Care Worker’s Employment Is Broader Than Approved Task List
Sep 23, 2014

Ohio Court Clarifies Elements of Retaliatory Discharge Action Against Former Employer

In Onderko v. Sierra Lobo, Inc., 2014 Ohio App. LEXIS 4015 (Sept. 19, 2014), an Ohio appellate court recently held that in order to state a claim for retaliatory discharge,...

Ohio Court Clarifies Elements of Retaliatory Discharge Action Against Former Employer Ohio Court Clarifies Elements of Retaliatory Discharge Action Against Former Employer

New Comments

  • 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
  • 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...