IL - Worker's Condition of Ill-Being Only Partially Related to Work
11/19/2025 | 0
The Illinois Appellate Court upheld a determination that a worker’s condition of ill-being was only partially related to his work injury.
Wilfredo Cruz worked for Rizza Cadillac as an auto technician. In November 2020, he allegedly slipped and fell while performing a tire rotation. Cruz claimed he fell backwards, hitting his head on the ground, and that a tire fell on his head. According to Cruz, he lost consciousness.
The next day, Cruz went to the hospital complaining of pain in the back right side of his head, nausea, and headache. Cruz did not mention losing consciousness. A comput...
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A Louisiana appellate court revived a school district employee’s intentional tort claim against her employer for her injuries from being attacked by a student.
Case: Bernier v. St. Tammany Parish School Board, No. 2025 CA 0260, 11/07/2025, published.
Facts: Lori Bernier worked for the St. Tammany Parish School Board as a paraprofessional at Covington Elementary.
She claimed she was injured when a third-grade student attacked her in October 2022. She alleged the student had stabbed another student with a fork earlier that same day.
Procedural history: Bernier filed a civil suit agains...
The Massachusetts Appeals Court upheld an award of benefits to a flight attendant for a broken finger.
Case: Joseph’s Case, No. 24-P-1387, 11/12/2025, unpublished.
Facts: Emmanuel F. Joseph worked for JetBlue Airways Corp. as a flight attendant. He alleged a food cart crushed his hand during a November 2020 flight from Fort Lauderdale to Boston.
A doctor diagnosed Joseph with a fracture of his fourth metacarpal four days later.
Procedural history: An administrative judge found Joseph credible and determined the hand injury was compensable.
Analysis: The Massachusetts Appeals Court n...
The Arizona Court of Appeals upheld the denial of a worker’s claim of injury to his back after less than a week on the job.
Case: Lopez v. Industrial Commission, No. 2 CA-IC 2025-0005, 11/10/2025, unpublished.
Facts: Central Arizona Block Inc. hired Rene Rodriguez Lopez on Nov. 21, 2023.
On Nov. 27, 2023, Lopez assisted in moving cinder blocks at work. The following day, with assistance from a bilingual coworker, Lopez informed a general manager that he could not continue to work due to the strain on his back.
The manager directed him to clock out and meet in the office, where ...
As of Oct. 30, 2025, Pennsylvania first responders may file a workers’ compensation claim for post-traumatic stress injuries (PTSIs) that result from certain qualifying events.
Crucially, Act No. 121, Workers’ Compensation Act-Compensation for Post-Traumatic Stress Injury, eliminates the requirement that the trauma be due to an “abnormal working condition.” Trauma from several types of events common to first responders' work now qualify as compensable.
This legislation makes it drastically easier for firs...
The California Division of Workers' Compensation announced additional changes to the hospital outpatient departments and ambulatory surgical centers section of the Official Medical Fee Schedule to incorporate changes made by Medicare.
On Oct. 3, the division issued an order adjusting the outpatient and ASC fee schedules based on quarterly changes in the Medicare system.
On Nov. 7, the U.S. Centers for Medicare and Medicaid Services issued revised fee schedule documents.
The DWC said it is incorporating into the fee schedule the CMS "Ambulatory Surgical Centers Payment Rates —...
Members of policy committees in both chambers of the Washington State Legislature will discuss workers' compensation issues at meetings on Dec. 5.
The Senate Labor and Commerce Committee is slated to discuss workers' compensation issues, including medical treatment and medical provider networks, according to a meeting notice. Additional details were not immediately available.
Meanwhile, the House Labor and Workplace Standards Committee is scheduled to hear an update from the Department of Labor and Industries, the agency that administers Washington's workers' compensation sys...
A Pennsylvania state senator introduced legislation that would increase benefits for workers who suffer serious and permanently disfiguring injuries on the job.
SB 1094, by Sen. Nick Pisciottano, D-Allegheny, was referred to the Senate Committee on Labor and Industry on Monday.
The bill would provide benefits for permanent disfigurement to any part of the body, not just the head, neck or face, and would make benefits for serious and permanent disfigurement available for 400 weeks instead of 275 weeks.
"Permanent scarring or disfigurement from a workplace injury is devastating, rega...
A bill introduced in Florida would allow first responders to rely on a preemployment physical examination conducted before they started working for a former employer to establish the presumption that certain diseases arose from employment.
Tuberculosis, heart disease and hypertension are presumptive occupational diseases for law enforcement, firefighters, correctional officers and probation officers.
Workers must undergo a preemployment physical exam that fails to revent any evidence of the conditions to qualify for the presumption.
SB 330, by Sen. Jennifer Bradley, R-Fleming Island, wo...
The Special Investigative Unit of RJN Investigations, Inc. was recently notified of a felony arrest based upon a documented fraud referral. In this case, the claimant was employed as a caretaker of the California Department of Social Services - I.H.S.S. At the time of the claimant's deposition, he appeared wearing a back support and ambulating with the aid of a cane. Proactively,...
The Idaho Supreme Court upheld the denial of a widow’s workers’ compensation claim for her husband’s death from complications related to COVID-19.
William Weeks worked for Oneida County’s Road and Bridge Department.
In September 2021, the county had high transmission rates for COVID-19 and recommended some of its employees take precautions including social distancing and not holding in-person meetings. However, critical workers including those in the Road and Bridge Department had to work their normal schedules.
The department continued to hold morning meetings in an...
A Texas appellate court ruled that a jail employee’s civil claims arising from a sexual assault by an inmate should have been dismissed.
Case: Harris County v. Doe, No. 01-24-00096-CV, 11/13/2025, published.
Facts: A female Harris County Jail employee, identified in court documents as Jane Doe, alleged that she was sexually assaulted by an inmate while at work in December 2021.
Doe claims she screamed and cried for help, but no one came due to understaffing at the jail.
Procedural history: Doe filed suit against the inmate, the county, and various individual county officials in their...
A Texas appellate court dismissed a worker’s challenge to the denial of her claim due to a lack of jurisdiction.
Case: Lee v. Grand Prairie Independent School District, No. 03-25-00243-CV, 11/13/2025, published.
Facts: Phyllis Lee was injured in Septemner 2017 working for the self-insured Grand Prairie Independent School District.
Procedural history: An administrative law judge found that Lee was barred from pursuing her diagnosis of post-traumatic stress disorder and a right rotator cuff tear as compensable injuries. The ALJ also found that Lee was barred from pursuing disability fro...
The Idaho Supreme Court ruled that only an injured worker may make and file with the Industrial Commission an application requesting a hearing when the underlying claim relates to unpaid or discontinued compensation or income benefits.
Case: Coronado v. City of Boise, No. 51722, 11/14/2025, published.
Facts: Sherri Coronado worked as a police officer for the City of Boise. On May 29, 2019, she suffered an injury to her right hip after she was dragged by and thrown from a motor vehicle while attempting to prevent a suspect from driving away.
The city’s claims administrator accepted Cor...
Florida Insurance Commissioner Mike Yaworsky on Monday announced the approval of a 6.9% rate decrease for policies incepting on or after Jan. 1.
The National Council on Compensation Insurance in September recommended the rate reduction based on improved loss experience in policy years 2022-2024 and continued decreases in claim frequency.
NCCI said at the time that claim frequency decreased at a faster pace in 2024 than the long-term average rate of decline.
Increased utilization of medical services was the primary driver of higher medical costs, while wage growth drove increases in indemnit...
The Texas Division of Workers' Compensation proposed rules that it said would clarify the process for carriers to get wage information for seasonal workers and to request adjustments to their wage average wage calculations.
The division said proposed amendments to Sections 128.3, 128.6, and 128.7 would correct obsolete references and update the text for plain language and agency style. Proposed amendments to Section 128.5 would clarify the process for insurance carriers to request adjustments to a seasonal employee’s average weekly wage and get wage information from seasonal employe...