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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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Sep 9, 2013

Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee

In the determination of any contested workers’ compensation claim, Hawaii favors the claimant with a presumption of compensability [HRS § 386–85]. Construing that presumption, a state appellate court recently affirmed...

Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee Hawaii: Employer Successfully Rebuts Presumption of Compensability Related to Chain-Smoking, Hypertensive Employee
Sep 7, 2013

Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable

Illustrating the significant deference given to the Commission’s factual findings, an Arkansas appellate court recently affirmed the denial of benefits to an employee who sustained injuries when he slipped and...

Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable Arkansas: Fall in Company Parking Lot While Returning Lunch Box is Not Compensable
Sep 4, 2013

Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits

In many states, the death benefit owed to a surviving spouse is commuted, sometimes at a significant discount, if the surviving spouse remarries. The Missouri statute, § 287.240(4)(a) R.S. Mo.,...

Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits Missouri: Surviving Spouse’s “Remarriage” Benefit Not Limited to Commutation of Her Share of Death Benefits
Aug 30, 2013

Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason

An Oregon appellate court recently affirmed a decision by the state’s Workers’ Compensation Board that concluded claimant’s subsistence and travel pay were “wages” for purposes of determining claimant’s TTD benefits...

Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason Oregon: AWW Must Include “Subsistence Allowance” and Travel Pay for California Brick Mason
Aug 30, 2013

New Hampshire: Intoxication, Without Showing of Causation, Is Insufficient to Defeat Comp Claim

Reiterating an important point, that in order to defeat a workers’ compensation claim it is generally insufficient to show that the injured worker was intoxicated at the time of the...

New Hampshire: Intoxication, Without Showing of Causation, Is Insufficient to Defeat Comp Claim New Hampshire: Intoxication, Without Showing of Causation, Is Insufficient to Defeat Comp Claim
Aug 27, 2013

Texas: No Arbitration Where Employer Could Not Show Employee Had Notice of Arbitration Agreement

Notice of the Texas non-subscribing employer’s occupational injury benefit plan was insufficient by itself to show that an employee had notice of an arbitration agreement referred to therein since the...

Texas: No Arbitration Where Employer Could Not Show Employee Had Notice of Arbitration Agreement Texas: No Arbitration Where Employer Could Not Show Employee Had Notice of Arbitration Agreement
Aug 26, 2013

Oklahoma: Chiropractors May Not Offer Expert Testimony as to Psychological Overlay

The Supreme Court of Oklahoma recently held that a chiropractor is not qualified as an expert in diagnosing psychological illnesses such as depression. Accordingly, the report of a chiropractor as...

Oklahoma: Chiropractors May Not Offer Expert Testimony as to Psychological Overlay Oklahoma: Chiropractors May Not Offer Expert Testimony as to Psychological Overlay
Aug 21, 2013

Colorado: Hotels and Restaurants Are Not “Medical Providers”

A Colorado appellate court recently held that hotels and restaurants that a workers’ compensation claimant patronized during authorized travel to obtain treatment by a specialist were not “medical providers” as...

Colorado: Hotels and Restaurants Are Not “Medical Providers” Colorado: Hotels and Restaurants Are Not “Medical Providers”
Aug 16, 2013

10th Circuit: Under Collateral Source Rule, Evidence of Discounted Med Pay to Medical Providers By Workers’ Comp Payer May Not Be Considered By Jury

In a complex medical malpractice diversity action involving multiple issues, the Tenth Circuit Court of Appeals recently affirmed a federal district court’s judgment on a $7 million verdict in favor...

10th Circuit: Under Collateral Source Rule, Evidence of Discounted Med Pay to Medical Providers By Workers’ Comp Payer May Not Be Considered By Jury 10th Circuit: Under Collateral Source Rule, Evidence of Discounted Med Pay to Medical Providers By Workers’ Comp Payer May Not Be Considered By Jury
Aug 15, 2013

Pennsylvania: 5-Minute Deviation Defeated Workers’ Comp Claim

Some years ago, my mentor, Arthur Larson, when commenting upon the issue of deviations within the workplace, wrote that courts generally recognize “that human beings do not run on tracks...

Pennsylvania: 5-Minute Deviation Defeated Workers’ Comp Claim Pennsylvania: 5-Minute Deviation Defeated Workers’ Comp Claim
Aug 7, 2013

Ninth Circuit Construes Longshore Act’s Intoxication Defense Provisions

The Longshore Act provides that no compensation shall be payable if the injury “was occasioned solely by the intoxication of the employee” [33 U.S.C.S. § 903(c), emphasis added]. The Ninth...

Ninth Circuit Construes Longshore Act’s Intoxication Defense Provisions Ninth Circuit Construes Longshore Act’s Intoxication Defense Provisions
Jul 27, 2013

California: Legal Secretary’s IIED Claim Against Attorney and Firm Related to Pornographic Emails May Proceed

In an unpublished decision, Elster v. Fishman, 2013 Cal. App. Unpub. LEXIS 5158 (July 22, 2013) [check Cal. Rules of Court, Rule 8.1115(a) regarding rules related to citation], a California...

California: Legal Secretary’s IIED Claim Against Attorney and Firm Related to Pornographic Emails May Proceed California: Legal Secretary’s IIED Claim Against Attorney and Firm Related to Pornographic Emails May Proceed

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.