Category: Case comment

Feb 18, 2019

Nurse Case Management Fees Not Part of Employer’s Subrogation Lien

Tennessee Employer Does Enjoy Lien for Disability Indemnity & Medical Expenses In a case of first impression, a Tennessee appellate court recently held that an employer does not enjoy a...

Nurse Case Management Fees Not Part of Employer’s Subrogation Lien Nurse Case Management Fees Not Part of Employer’s Subrogation Lien
Feb 18, 2019

Last Injurious Exposure: What Does “Impossible” Mean?

Oregon Court Says “Impossibility” May be Established by Medical “Probability” Oregon, like the majority of American jurisdictions, employs the “last injurious exposure” rule to assign liability among multiple employers in...

Last Injurious Exposure: What Does “Impossible” Mean? Last Injurious Exposure: What Does “Impossible” Mean?
Feb 14, 2019

Kansas Court of Appeals Jettisons 82-Year-Old Supreme Court Precedent

Employer’s Payment of Medical Charges Revives Expired Statute of Limitations Reversing the state’s Workers’ Compensation Board, which had relied upon what it thought was established precedent (i.e., a 1936 decision...

Kansas Court of Appeals Jettisons 82-Year-Old Supreme Court Precedent Kansas Court of Appeals Jettisons 82-Year-Old Supreme Court Precedent
Feb 14, 2019

Virginia Worker’s “Short-Cut” Results in Denial of Benefits

Violation of Known Safety Rule Prevents Recovery for Injuries A decision to enter a fenced area at the employer’s facility through an unapproved opening, instead of through the approved interlock...

Virginia Worker’s “Short-Cut” Results in Denial of Benefits Virginia Worker’s “Short-Cut” Results in Denial of Benefits
Feb 13, 2019

Virginia Court Affirms Professional Football Tryout’s AWW of $783.63

Potential $435K Annual Compensation Under Standard Contract Deemed Too Contingent The Court of Appeals of Virginia recently affirmed a determination by the state’s Workers’ Compensation Commission that fixed a professional...

Virginia Court Affirms Professional Football Tryout’s AWW of $783.63 Virginia Court Affirms Professional Football Tryout’s AWW of $783.63
Feb 7, 2019

Virginia Commission Should Have Considered Employment-Related Risks of Assault

Where an overnight attendant at a rest area was stabbed in the face by a former co-worker whose motive could not be determined—the assailant committed suicide later the same day—the...

Virginia Commission Should Have Considered Employment-Related Risks of Assault Virginia Commission Should Have Considered Employment-Related Risks of Assault
Feb 5, 2019

Arizona High Court Says Nebraska Law Prevents Absolute Assignment of Injured Worker’s Third-Party Claim

Dueling Statutes: Which State’s Subrogation Law Should Apply? Variables within America’s mobile economy often produce complex choice of law issues, particularly when it comes to employer/insurer subrogation interests. For example,...

Arizona High Court Says Nebraska Law Prevents Absolute Assignment of Injured Worker’s Third-Party Claim Arizona High Court Says Nebraska Law Prevents Absolute Assignment of Injured Worker’s Third-Party Claim
Feb 4, 2019

Tennessee: No Compensable Claim Where Employer Failed to Use On-Site Defibrillator

The Supreme Court of Tennessee, reversing a decision of a state trial court, held that an employer who failed to use an automated external defibrillator (AED) to assist an employee...

Tennessee: No Compensable Claim Where Employer Failed to Use On-Site Defibrillator Tennessee: No Compensable Claim Where Employer Failed to Use On-Site Defibrillator
Jan 17, 2019

Husband/Wife Bakery Ends Up With Two Policies; Insurers Must Split Cost of Death Claim

Policy Procured “by Mistake” Remains in Force Since Cancellation Wasn’t Done According to Missouri Law Cancellation of a workers’ compensation insurance policy, even when both the insured and the insurer...

Husband/Wife Bakery Ends Up With Two Policies; Insurers Must Split Cost of Death Claim Husband/Wife Bakery Ends Up With Two Policies; Insurers Must Split Cost of Death Claim
Jan 15, 2019

Florida Comp Act’s Drug-Free Workplace Program Statute Provides no Private Right of Action

Unsuccessful Job Applicant Sought to Utilize Statute After Passing Drug Test, But Not Getting Job § 440.102, Fla. Stat., which establishes a drug-free workplace program as part of Florida’s overall...

Florida Comp Act’s Drug-Free Workplace Program Statute Provides no Private Right of Action Florida Comp Act’s Drug-Free Workplace Program Statute Provides no Private Right of Action
Jan 14, 2019

Kentucky Considers PTSD Benefits—but Only for First Responders

Animal Farm Logic: “All [workers] are equal, but some [workers] are more equal than others.” House Bill 40, which would provide workers’ compensation benefits for post-traumatic stress disorders (PTSD), but...

Kentucky Considers PTSD Benefits—but Only for First Responders Kentucky Considers PTSD Benefits—but Only for First Responders
Dec 31, 2018

Ohio Bureau of Workers’ Comp Immune From Tort Liability for Alleged Faulty Inspections

An Ohio appellant court recently held that the state’s Bureau of Workers’ Compensation (“BWC”) was immune from tort liability in a civil action filed against it by the estate of...

Ohio Bureau of Workers’ Comp Immune From Tort Liability for Alleged Faulty Inspections Ohio Bureau of Workers’ Comp Immune From Tort Liability for Alleged Faulty Inspections