Category: Case comment

Oct 13, 2013

Louisiana: Boilermaker’s 39-Day Work Schedule, With One Day Off, Found to Cause Stroke

In Louisiana, when an employee seeks to recover workers’ compensation benefits for a heart-related or perivascular injury, he or she must prove, by clear and convincing evidence, that: (i) The...

Louisiana: Boilermaker’s 39-Day Work Schedule, With One Day Off, Found to Cause Stroke Louisiana: Boilermaker’s 39-Day Work Schedule, With One Day Off, Found to Cause Stroke
Oct 8, 2013

U.S. Supreme Court Will Not Hear Hutterite Colony’s Religious Exclusion Argument

Yesterday, the United States Supreme Court indicated that it would not hear a Montana Hutterite Colony’s argument that a 2009 amendment to a state statute [§ 39–71–307, MCA] violated the...

U.S. Supreme Court Will Not Hear Hutterite Colony’s Religious Exclusion Argument U.S. Supreme Court Will Not Hear Hutterite Colony’s Religious Exclusion Argument
Oct 1, 2013

Alabama: Work-Product Rule Protects Post-Injury Accident Report from Discovery

Last Friday, a divided Supreme Court of Alabama, applying the work-product rule, determined that a post-accident investigation report, conducted and prepared by an employer’s safety director and a co-worker and...

Alabama: Work-Product Rule Protects Post-Injury Accident Report from Discovery Alabama: Work-Product Rule Protects Post-Injury Accident Report from Discovery
Sep 27, 2013

CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court

In a decision officially to be released on Tuesday (October 1), the Supreme Court of Connecticut has affirmed a decision of the state’s Workers’ Compensation Review Board that in turn...

CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court CT: Commissioner’s Decision That Waiver of Comp Benefits Was Not Supported by Consideration Upheld by State Supreme Court
Sep 27, 2013

6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola

A divided en banc panel of the Sixth Circuit Court of Appeals has reversed a decision by a three-judge panel of the same Circuit Court that had allowed a RICO...

6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola 6th Circuit Bounces RICO Suit Against Sedgwick & Coca-Cola
Sep 19, 2013

Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails

Extensively quoting from Larson’s Workers’ Compensation Law and reiterating the state’s two-prong test to invoke the so-called “dual capacity doctrine” as an exception to the exclusive remedy provided by the...

Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails Illinois: Wrongful Death Action Against Employer Alleging “Dual Capacity” Fails
Sep 18, 2013

Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000

In Ohio, like most jurisdictions, an employer or carrier that provides an injured worker with workers’ compensation benefits enjoys a subrogation interest, to the extent of such payment, in any...

Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000 Ohio: Injured Employee Settles 3rd Party Claim for $15,000, Owes Subrogated Employer $61,000
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