Category: Case comment

Dec 10, 2018

Nevada Employer Need Not Show Knowledge of Specific Medical Diagnosis to Recover from Subsequent Injury Fund

In Nevada, under Nev. Rev. Stat. § 616B.578, in order for an employer to receive reimbursement from the state’s “Subsequent Injury Account,” it must prove that that it had knowledge...

Nevada Employer Need Not Show Knowledge of Specific Medical Diagnosis to Recover from Subsequent Injury Fund Nevada Employer Need Not Show Knowledge of Specific Medical Diagnosis to Recover from Subsequent Injury Fund
Dec 10, 2018

29-Month Delay in Filing North Dakota Claim Bars Recovery

The Supreme Court of North Dakota recently affirmed an ALJ’s finding that the filing of a worker’s claim some 29 months after the work incident was not timely, and, therefore,...

29-Month Delay in Filing North Dakota Claim Bars Recovery 29-Month Delay in Filing North Dakota Claim Bars Recovery
Dec 3, 2018

New York Court Says Attorney’s Ex Parte Text Message to Physician Was Harmless

In a divided decision, a New York appellate court recently held that the state’s Workers’ Compensation Board abused its discretion when it excluded from the record a physician’s medical report...

New York Court Says Attorney’s Ex Parte Text Message to Physician Was Harmless New York Court Says Attorney’s Ex Parte Text Message to Physician Was Harmless
Nov 27, 2018

Divided PA Supreme Court Refuses to Allow Comp Carrier to Maintain Third-Party Action on Behalf of Injured Employee

Injured Employee Must Either Assign Cause or Join Litigation as Party Plaintiff In Pennsylvania, a workers’ compensation insurance carrier may not maintain a third-party action against an alleged tortfeasor on...

Divided PA Supreme Court Refuses to Allow Comp Carrier to Maintain Third-Party Action on Behalf of Injured Employee Divided PA Supreme Court Refuses to Allow Comp Carrier to Maintain Third-Party Action on Behalf of Injured Employee
Nov 21, 2018

Massachusetts Retaliatory Discharge Statute Protects Employee’s Right to Sue Employer in Tort

A provision of the Massachusetts Workers’ Compensation Act (Act), Mass. Gen. Laws ch. 152, § 75B(2), and not the common law, affords an employee who was injured on the job...

Massachusetts Retaliatory Discharge Statute Protects Employee’s Right to Sue Employer in Tort Massachusetts Retaliatory Discharge Statute Protects Employee’s Right to Sue Employer in Tort
Nov 20, 2018

Idiopathic Fall to Level Floor May Be Compensable in Iowa

Divided Court Adopts Minority Rule for Idiopathic Falls Adopting the minority American rule that all work-related risk factors must be considered in determining the compensability of an idiopathic fall—even the...

Idiopathic Fall to Level Floor May Be Compensable in Iowa Idiopathic Fall to Level Floor May Be Compensable in Iowa
Nov 19, 2018

Massive Stroke After MMI Does Not Result in Loss of Nebraska PTD Benefits

Where an employee sustained work-related injuries, reached maximum medical improvement (MMI), and, based on factual findings by Nebraska’s Workers’ Compensation Court (WCC), was adjudged to be permanently and totally disabled,...

Massive Stroke After MMI Does Not Result in Loss of Nebraska PTD Benefits Massive Stroke After MMI Does Not Result in Loss of Nebraska PTD Benefits
Nov 19, 2018

NY’s Medical Treatment Guidelines Apply to Out-of-State Providers Treating Nonresident Claimants

In a decision that could have significant repercussions for a number of claimants under the New York Workers’ Compensation Law, a state appellate court affirmed a decision of the Workers’...

NY’s Medical Treatment Guidelines Apply to Out-of-State Providers Treating Nonresident Claimants NY’s Medical Treatment Guidelines Apply to Out-of-State Providers Treating Nonresident Claimants
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 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