Showing posts with label workers compensation law. Show all posts
Showing posts with label workers compensation law. Show all posts

Tuesday, August 19, 2014

New Obama "Fair and Safe Workplaces" law: All hail the new safe workplace?

Controversy reigns over the "Fair and Safe Workplaces" Executive Order that Obama signed into law on August 5th

Those with labor law violations may be forced to disclose them publicly in order to secure big contracts. This can be a bit of a game-changer when it comes to deciding whether to bother contesting smaller OSHA citations. Whereas companies may've previously decided sometimes that it wasn't worth the bother--just pay the fine and be done with it--in light of this new law it may be worth it to contest them in hopes of wiping the record clean.

The other faction argues that this scores another Obama coup for the common worker, that it may help create a safer workplace.

“This is one of the most important positive steps for civil rights in the last 20 years,” says Paul Bland, executive director of Public Justice, a public-interest law group.

That may be a reference to the second part of the new law, which states that companies with federal contracts exceeding a cool million cannot force employees into arbitration and out of the limelight of court. But not everyone with a voice uses it for just purposes.


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Located in the Denver Metro area.
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Any content of this blog is intended for informational purposes only.It is not intended to solicit business, provide legal advice from The Law Office of O'Toole & Sbarbaro, P.C. and does not serve as a medium for an attorney-client relationship. Therefore, The Law Office of O'Toole & Sbarbaro, P.C. is not responsible for the information on this blog which may not apply to every reader. Always seek professional counsel if you have any legal matters. Contents within the blog of The Law Office of O'Toole & Sbarbaro, P.C., logos and other related media are protected by the copyright laws of the United States and other jurisdictions.

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Wednesday, June 11, 2014

Colorado Jurisdiction: - Law Office of O'Toole & Sbarbaro, P.C.

From the archives of the Law of Office O'Toole & Sbarbaro, P.C.

Colorado jurisdiction over injuries suffered outside of the state is conferred by §8-41-204, C.R.S.  This statute provides that Colorado has jurisdiction over out-of-state injuries if the employee was “hired or is regularly employed in this state.”  Whether an employee was “hired … in this state” is a contract question generally governed by the same rules as other contracts.  Denver Truck Exchange v. Perryman, 134 Colo. 586, 307 P.2d 805 (1957).  The essential elements of a contract are competent parties, subject matter, legal consideration, mutuality of agreement, and mutuality of obligation.  Id.  The place of contracting is generally determined by the parties’ intention, and is usually the place where the offer is accepted, or the last act necessary to the meeting of the minds or to complete the contract is performed.  Aspen Highlands Skiing Corp. v. Apostolou,  866 P.2d 1384 (Colo. 1994).

            In Moorhead Machinery & Boiler Co. v. Del Valle, 934 P.2d 861 (Colo. App. 1996) abrogated on other grounds by Horodyskyj v. Karanian, 32 P.3d 740 (Colo. 2001), the court noted that the rule in Denver Truck Exchange has been tempered so that a contract of hire may be deemed formed, even though not every formality attending commercial contractual arrangements is observed, as long as the fundamental elements of contract formation are present.  See also 1A A. Larson, Workmen’s Compensation Law §26.22 at 5-325 (1995)(it is necessary “[to subordinate] contract law technicalities to the reality of the [employment] relationship existing from the time the claimant [began] his journey toward the job pursuant to the overall-contract governing the way hiring is done in this particular employment”).


            The question of whether the claimant has proven the existence of a contract for hire is one of fact for determination by the ALJ.  Rocky Mountain Dairy Products v. Pease, 161 Colo. 216, 422 P.2d 630 (1996).  Similarly, the nature of the last act necessary to complete the contract and its location are generally factual questions for the ALJ’s resolution.

Contact Neil O'Toole and John Sbarbaro
Phone: 303-595-4777
Located in the Denver Metro area.
226 West 12th Avenue Denver, Colorado 80204

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Any content of this blog is intended for informational purposes only.It is not intended to solicit business, provide legal advice from The Law Office of O'Toole & Sbarbaro, P.C. and does not serve as a medium for an attorney-client relationship. Therefore, The Law Office of O'Toole & Sbarbaro, P.C. is not responsible for the information on this blog which may not apply to every reader. Always seek professional counsel if you have any legal matters. Contents within the blog of The Law Office of O'Toole & Sbarbaro, P.C., logos and other related media are protected by the copyright laws of the United States and other jurisdictions.


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Monday, September 23, 2013

Automated Adjudication = Automatic Waste

By  
I look at all of my bills.  Not just during work for business matters, but my personal bills as well.  I do not catch many errors.  In fact I think I have only caught maybe a handful of issues my entire life.  These weren’t big issues, sometimes they were just duplicate charges, service fees that were supposed to be waived, or deposits on hotels that were supposed to be waived because I rescheduled within the allotted time frame without penalty.

Of course I know of people that just pay their bills online automatically every month.  They don’t review the itemized statements, nor do they even read the automated email notifications saying their bills were due and automatically paid per their own permission.  For obvious reasons this drives me crazy.  Humans sometimes fail.  Systems sometimes fail.  Mistakes happen.  No matter how insignificant the duty may be, these risks of errors are always out there every day.  Not just in billing matters, but in everything.  My coffee order gets prepared incorrectly.  My salad came with the dressing on the salad instead of on the side.  Don’t even get me started about other issues involving flights being “on-time,” The point is to err is human, and last time I checked we were all human at least to some degree, especially in this industry.


Claims Industry Working To Become More Efficient

The latest craze is the argument over automated adjudication of minor claims and of lifetime claims that have steadied out as far as invasive treatment goes.  Adjusters are busy, and insurers/TPAs are trying to do more with less.  They want to become more efficient.  They want to spend less and less time on what they deem to be “trivial” claims and spend more time on the more important claims that carry a higher exposure. 

This makes sense.  Adjusters should be spending more and more time focusing on the matters that are more important than Jim Worker who cut his finger and had to go to the doctor for a few stitches.  Minor medical-only claims constitute a lot of the pending file counts on certain levels of adjusters, and those adjusters are also the ones that are just starting out in the claims world.  This is where they should be learning the process, and how important it is to review every bill for relatedness.

But to introduce automatic claim handling by a computer worries me.  I worry about leakage all the time, because wasting money is one of my many pet-peeves.  The marketers of automated claim technology say that they protect against error, because of the data that has to be input into the system for a person.  Date timeframes need to be in place.  Body injury codes are input so the injury body part can be correctly identified.  CPT codes and billing coding is also entered into the system to prevent certain treatments from being automatically paid.  Maximum bill amount parameters can be placed so any big bill they may come in would be flagged and not paid so the adjuster can review and authorize the payment.

These are all well and good.  In fact, it looks great!  If this system works according to plan, then how could anything ever be paid in error?  On paper, these automated systems appear to be the next greatest thing since the computer so adjusters can do more and become more proactive at their desks.  So what could the problem possibly be with implementing an automated adjudication process?

I can tell you one problem right now—it would only be as good as the person inputting the information.  Like I said above—to err is human. 


Automated Adjudication on Lifetime Claims = Large Medical Leakage

Let’s say automated adjudication is used for lifetime claims.  After all, you have accepted the left knee as being compensable for life.  You owe it, and you owe treatment on it, depending on your jurisdiction.  But for ease of an example, we will just say you owe it no matter what.  So it makes sense to just automate the medical bill payment on it, right?

No it does not.  And I will tell you why:  What if the doctor this person treats with just has their left knee as the primary diagnosis?  This injured worker treats with their primary care doc.  In the doctor’s system, they have the injured worker down as the left knee being most important and primary diagnosis.  But if he comes in for a non-work related back strain, I doubt the primary diagnosis will change.  The CPT code would probably just be for an office visit, so the system has no idea that the person treated for their back because it just sees the diagnosis code, and the CPT code.  Nobody is there to view the medical report, so this bill gets paid.  Along with bills for the flu, arm pain, lab results, medication of various types for various elements, and so on.  Now you have paid the medical bills for who knows what, for who knows how many years.  That is a leakage emergency!! 

When will this be corrected?  Who is in charge of making sure the treatment is for the compensable knee?  The answer is probably nobody.  Plus this can happen on a number of claims.  Add all of that up, and now you have a substantial number of medical leakage.  One that should have never occurred in the first place if you had a real person reviewing medical notes that go with the bill before they paid it.

I saw a fantastic statistic from  Acrometis in an article on their website entitled “How much is your auto-adjudication costing you?” (http://www.acrometis.com/strength/0123.htm)   In this article, Acrometis states that “…auto-approving all submissions under $250 results in overpaying $8,000,000 if you only look at submissions that were returned but not resubmitted.  Applying the same approach to all the submissions analyzed results in overpayment of more than $133,000,000.”

Now I could stand a bill here and there being paid in error.  But you have to look at the total from a macroeconomic view.  Look at the entire scope of a carrier/TPA, not just on the one claim itself.


Auto Accepting Bills May Accept Large and Unrelated Medical Services

Lastly and yet another great point in that article shows that auto-accepting some bills may loop you into also accepting much larger and potentially unrelated medical services.  This could include costly prescriptions, DME bills, unwarranted exploratory surgical procedures, and so on.  This would depend on your jurisdiction, but the end result is the nightmare that every adjuster has, which is being forced to accept treatment on an unrelated non-compensable body part due to adjuster error.  This is going to land the adjuster in some hot water, and probable disciplinary action I would hope.  This type of error is inexcusable!

All of these errors do not need to happen, and should not happen at all.  They should not happen because adjusting claims should be done by a real person, not some automated service.  Before we jump on the ship of automatic adjudicating, we had better take a step back and look at the consequences of error, both from a human standpoint and from a systems standpoint.
Original Source

The Law Office of O'Toole & Sbarbaro, P.C. can help you with your workers' compensation or Social Security disability case.
http://www.otoole-sbarbaro.com
Phone: 303-595-4777
We are located in the Denver Metro area.
226 West 12th Avenue Denver, Colorado 80204

Disclaimer 
Any content of this blog is intended for informational purposes only.It is not intended to solicit business, provide legal advice from The Law Office of O'Toole & Sbarbaro, P.C. and does not serve as a medium for an attorney-client relationship. Therefore, The Law Office of O'Toole & Sbarbaro, P.C. is not responsible for the information on this blog which may not apply to every reader. Always seek professional counsel if you have any legal matters. Contents within the blog of The Law Office of O'Toole & Sbarbaro, P.C., logos and other related media are protected by the copyright laws of the United States and other jurisdictions.

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Thursday, September 12, 2013

Back to Routine Doesn't Mean Back in Pain - The Law Office of O'Toole & Sbarbaro, P.C. - Workers Comp Blog

By  

Portland, ME (WorkersCompensation.com) - Back to school and back to work often means more time at a desk and in front of a computer screen. But those old desk jockey aches and pains don't have to return with you from your summer vacation.
According to the U.S. Bureau of Labor Statistics, musculoskeletal injuries caused by poor ergonomics take nearly 400,000 workers out of work for an average of 8 days each year. And, while many of us can't avoid sitting in front of a computer for several hours a day, there are ways to decrease your chances of injury and time lost from work or school.
The first step is often an ergonomic evaluation of your work area and your body positioning as you sit at your computer. Here are some recommendations from MEMIC's Chief Ergonomist Allan Brown:
  • Position your head so your ears are over your shoulders
  • Place screen monitor 18-24 inches from your eyes
  • Adjust your monitor's height so it's in direct line of your sight
  • Relax your shoulders
  • Keep upper arms in line with your torso
  • Put elbows at 90 degrees with arms comfortably at your side
  • Make sure wrists are in neutral posture; not be bent up or down
  • Place mouse on same plane as your keyboard
  • Use a chair with a good lumbar support
  • Keep feet flat on the floor; if your feet don't reach the floor, use a foot rest
If you don't have access to an ergonomics expert or are unsure of your positioning, have a friend snap a picture of you at your workstation to see what your posture looks like.
But perhaps the most important piece of advice is to get up and move. Every hour you should take a stretch, go for a walk, talk to a friend, but make sure to get up and move throughout your day. Whatever your new fall routine looks like, make good ergonomics a part of it.

This article is part of the MEMIC Summer Safety Series.

Original Source


The Law Office of O'Toole & Sbarbaro, P.C. can help you with your workers' compensation or Social Security disability case.
http://www.otoole-sbarbaro.com
Phone: 303-595-4777
We are located in the Denver Metro area.
226 West 12th Avenue Denver, Colorado 80204

Disclaimer 
Any content of this blog is intended for informational purposes only.It is not intended to solicit business, provide legal advice from The Law Office of O'Toole & Sbarbaro, P.C. and does not serve as a medium for an attorney-client relationship. Therefore, The Law Office of O'Toole & Sbarbaro, P.C. is not responsible for the information on this blog which may not apply to every reader. Always seek professional counsel if you have any legal matters. Contents within the blog of The Law Office of O'Toole & Sbarbaro, P.C., logos and other related media are protected by the copyright laws of the United States and other jurisdictions.

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Wednesday, September 11, 2013

The Deadly Symmetry In Work Comp. A Stick With Two Short Ends - The Law Office of O'Toole & Sbarbaro, P.C.

There is a decades old ongoing discussion in work comp: is it the employer or employee who benefits or loses? The answer: both.


Neither Employer of Employee Are “Winners” in Work Comp

Neither the employer (who, ultimately, pays for everything) nor the employee (who has substantial net wage loss in nearly every claim) can be said to “win”, no matter what the outcome. “Winning”, to most people, means emerging undamaged, but the net losses in comp sometimes remain unknown to the parties until years later.

The most perfidious feature of work comp laws is the “substantial evidence” rule, which permits a comp board ruling to be unreviewable on questions of fact and medical opinion if it is supported by “substantial evidence”, which, in fact, is defined as “a scintilla of evidence”, which is hardly substantial at all.

So what? Well, it means that a typical comp system can make inconsistent rulings on a large group of claims, but each will be based on “substantial evidence” even though the rulings in bulk are contradictory. Comp systems have noticed this since the beginning, and so have the lowliest ALJs, who quickly realize that they are shielded from review, except on questions of law, not fact.  So, no matter who might win a particular claim, all can become the next victim of “substantial evidence”.


Case Law Decisions Lead to Predictable Outcomes Most of the Time

But “a scintilla of evidence” is not a rule which demands the best of any system. It leads to decisions which erode into predictable outcomes most of the time, warranted or not, punctuated by irrational outcomes for no apparent reasons. One NY comp case, in the 1980s, was so inexplicable that it made a list of outrageous decisions which was published in the Readers’ Digest.

The comp claim involved a high school teacher who was so “stressed” by work that he shot and killed the principal. And then went on to win a max rate “stress claim”. This was upheld by the highest court in NY based on “substantial evidence”. The principal’s widow, in turn, had no problem winning a death claim, also based on – “substantial evidence”.

Therefore, neither party got the “short end” since both “won”.

If the result of a claim is only measured by who got money or who did not, the real “winners” and “losers” can never be identified. In the above high school case, what was the true effect on workplace morale? Was it ever considered?  What was the successor principal faced with in terms of maintaining discipline and integrity in the school system?
 By  
And what did the attorneys representing workers do with that decision? For years it was routinely cited as authority for “all doubts are resolved in the worker’s favor”, although what doubt was in that claim is difficult to imagine.

The teacher later gave an interview to a newspaper, after his win in the highest court, complaining of the “stress” the litigation had subjected him to.

So who wins every comp claim? Everyone but the employer and employee.


Editor Michael B. Stack, CPA, Director of Operations, Amaxx Risk Solutions, Inc. is an expert in employer communication systems and part of the Amaxx team helping companies reduce their workers compensation costs by 20% to 50%. He is a writer, speaker, and website publisher. www.reduceyourworkerscomp.com. Contact: mstack@reduceyourworkerscomp.com.  

©2013 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

Original Source

The Law Office of O'Toole & Sbarbaro, P.C. can help you with your workers' compensation or Social Security disability case.
http://www.otoole-sbarbaro.com
Phone: 303-595-4777
We are located in the Denver Metro area.
226 West 12th Avenue Denver, Colorado 80204

Disclaimer 
Any content of this blog is intended for informational purposes only.It is not intended to solicit business, provide legal advice from The Law Office of O'Toole & Sbarbaro, P.C. and does not serve as a medium for an attorney-client relationship. Therefore, The Law Office of O'Toole & Sbarbaro, P.C. is not responsible for the information on this blog which may not apply to every reader. Always seek professional counsel if you have any legal matters. Contents within the blog of The Law Office of O'Toole & Sbarbaro, P.C., logos and other related media are protected by the copyright laws of the United States and other jurisdictions.

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Monday, September 9, 2013

Commission Keeps Claimant's Counsel and Recording Devices out of Employer's Medical Evaluations

September 5, 2013
by Merrilee Harrell 
A recent decision of the Alaska Workers’ Compensation Appeals Commission concluded that claimant’s counsel may not attend and record an employer’s independent medical evaluation (EME) unless the examining physician consents. InASRC Energy Services, Inc. v. Kollman, AWCAC Decision No. 186 (August 21, 2013), the Commission reversed an interlocutory decision of the Alaska Workers’ Compensation Board that injured worker Jeffrey Kollman may record an EME and have a witness present despite the objection of the employer’s physicians. Kollman v. ASRC Energy Services, Inc., AWCB Decision No. 13-0076 (June 27, 2013). The Board had relied onLangfeldt-Haaland v. Saupe Enterprises, 768 P.2d 1144 (Alaska 1989), which held that a civil litigant had a right to record a court-ordered Rule 35 medical evaluation and have his attorney present during the evaluation. On appeal, the Commission noted that Civil Rule 35 is significantly different from AS 23.30.095(e) of the Alaska Workers’ Compensation Act. AS 23.30.095(e) states that “The employee shall... submit to an examination by a physician or surgeon of the employer’s choice...” which, the Commission noted, leaves the choice of EME physician exclusively with the employer. A Rule 35 medical evaluation, in contrast, may be ordered by a judge “only on motion for good cause shown and upon notice... to all parties and shall specify the time, place, manner, conditions, and scope of the examination and the person or persons by whom it is to be made.” 
The Commission also noted that Langfeldt-Haaland was a 3-2 decision that explicitly limited its holding to Civil Rule 35 medical evaluations. The majority had argued the importance of allowing counsel to “observe shortcomings and improprieties during the examination which could be the subject of inquiries on cross-examination at trial; and ... [to] object to questions posed to the plaintiff during the examination that concern privileged information.” The dissenting judges pointed out that “adopting such a rule could have a chilling effect on otherwise reputable physicians performing medical examinations.” The Commission found the dissent’s position more persuasive, and also took into account a survey of SIME physicians that showed a significant percentage of the physicians surveyed would decline to perform evaluations if they were required to allow the evaluation to be witnessed and recorded. Requiring EME evaluations to be witnessed and recorded would thus have a chilling effect on the employer’s choice of physician if the employer’s choice was limited by such a requirement.  
The commission emphasized that the plain language of AS 23.30.095(e) gives the employer the exclusive choice of EME physician, noting that the statute “does not say that the choice of an EME physician is exclusively the employer’s, provided that the employer chooses a physician who would allow witnessing and recording of the EME.” The commission concluded that such a restriction would interfere with the employer’s choice of physician as contemplated by AS 23.30.095(e). Kollman has appealed the Commission’s ruling to the Alaska Supreme Court.

Original Source

Contact the Law Office of O'Toole & Sbarbaro, P.C. today if you have a workers' compensation or a Social Security disability case.
Phone: 303-595-4777
We are located in the Denver Metro area.
226 West 12th Avenue Denver, Colorado 80204

Disclaimer 
Any content of this blog is intended for informational purposes only.It is not intended to solicit business, provide legal advice from The Law Office of O'Toole & Sbarbaro, P.C. and does not serve as a medium for an attorney-client relationship. Therefore, The Law Office of O'Toole & Sbarbaro, P.C. is not responsible for the information on this blog which may not apply to every reader. Always seek professional counsel if you have any legal matters. Contents within the blog of The Law Office of O'Toole & Sbarbaro, P.C., logos and other related media are protected by the copyright laws of the United States and other jurisdictions.

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Thursday, August 8, 2013

S. Dakota Workers' Comp Claim for Mom Slain on Job Tests Law












The night after being served with divorce papers, Steven Tassler 
shot and killed his wife, Julie Tassler, while she was taking her 
15 minute-break in the parking lot of the bank processing center
where she worked, before taking his own life.

Wednesday, August 7, 2013

Court: No Workers' Comp in Drunk Dockworker Case

PORTLAND, Ore. August 2, 2013 (AP)

A federal appeals court says an Oregon longshoreman who got drunk on the job, urinated while standing on a dock and then fell 6 feet onto concrete should not get workers' compensation benefits for his injuries.
Gary Schwirse drank at least nine beers and half-pint of whiskey on Jan. 8, 2006. While standing on a dock, he urinated and fell over a railing. At the hospital, he registered a blood-alcohol level of 0.25 percent.
Schwirse sued for workers' compensation benefits and at first was victorious, when an administrative law judge ruled that workplace hazards had been a factor in his fall. But the judge later reversed his ruling when Schwirse backed off a claim that he tripped over an orange cone.
The worker appealed it to U.S. District Court, where he lost, and the case landed in the 9th U.S. Circuit Court of Appeals, which denied a petition for a review of claims this week. The court said his injuries were due solely to intoxication and his employers could not be held responsible.
Schwirse later tried to argue that the very concrete onto which he fell, and not his intoxication, was responsible for his injuries. That argument also lost.
Ninth Circuit Court of Appeals judge N. Randy Smith wrote in the opinion that if intoxication was the reason for the fall, then intoxication was also the reason for the injury.
Schwirse's Sunday morning began like this: He drank two beers before 8 a.m. and three beers once he got to work. At noon, he had another four or five beers, then started in on a pint of whiskey, of which he drank about half. At 4:30 p.m., when his shift collecting cones and directing trucks was over, he walked to a railing at the dock to urinate.
He fell up and over the rail onto a concrete and steel ledge. He suffered a cut to his right temple.
The Marine Terminals Corp. refused to pay his benefits, arguing that his intoxication was the sole cause of his injury. Schwirse then gave conflicting stories as to what happened that day.
At his first hearing before an administrative law judge, Schwirse said two coworkers told him he tripped over an orange cone. That testimony conflicted with a previous deposition in which he said he himself remembered tripping over the cone.
The judge initially awarded Schwirse benefits. The case bounced between the administrative law judge and the Benefits Review Board, which eventually ruled against the worker.

 Original Source

Contact the Law Office of O'Toole & Sbarbaro, P.C. today if you have a workers' compensation or a Social Security disability case.
Phone: 303-595-4777
We are located in the Denver Metro area.
226 West 12th Avenue Denver, Colorado 80204

Disclaimer 
Any content of this blog is intended for informational purposes only.It is not intended to solicit business, provide legal advice from The Law Office of O'Toole & Sbarbaro, P.C. and does not serve as a medium for an attorney-client relationship. Therefore, The Law Office of O'Toole & Sbarbaro, P.C. is not responsible for the information on this blog which may not apply to every reader. Always seek professional counsel if you have any legal matters. Contents within the blog of The Law Office of O'Toole & Sbarbaro, P.C., logos and other related media are protected by the copyright laws of the United States and other jurisdictions.

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Friday, August 2, 2013

A key decision in football cases was decided by the Workers’ Compensation Appeals Board (WCAB)



  • Posted By: 

  • July 1, 2013



  • The applicant was a professional football player. The applicant resided in Florida. He signed a professional football contract with New Orleans outside of the State of California. While employed with New Orleans he played 5 of his 32 games in the State of California. He also played for the Bengals and played 1 of 16 games in California. He filed a cumulative trauma case in California, after retirement.
    The Workers’ Compensation Judge (WCJ) found the applicant suffered a cumulative trauma and awarded the applicant a 40 percent disability. The team appealed.
    The WCAB found the applicant and the employer are exempt from California law where the applicant was hired outside the state and under the following conditions: The applicant temporarily works in California, the employer provided workers’ compensation coverage in another state (here it was Ohio), if the other state recognizes California’s extraterritorial provisions, if the other state exempts California from coverage of California’s workers’ compensation laws.
    This was the case here, thus California did not have to pay benefits.
    Case: Carrroll V. Cincinatti Bengals
    Read original story here


    Contact the Law Office of O'Toole & Sbarbaro, P.C. today if you have a workers' compensation or a Social Security disability case.
    Phone: 303-595-4777
    We are located in the Denver Metro area.
    226 West 12th Avenue Denver, Colorado 80204

    Disclaimer 
    Any content of this blog is intended for informational purposes only.It is not intended to solicit business, provide legal advice from The Law Office of O'Toole & Sbarbaro, P.C. and does not serve as a medium for an attorney-client relationship. Therefore, The Law Office of O'Toole & Sbarbaro, P.C. is not responsible for the information on this blog which may not apply to every reader. Always seek professional counsel if you have any legal matters. Contents within the blog of The Law Office of O'Toole & Sbarbaro, P.C., logos and other related media are protected by the copyright laws of the United States and other jurisdictions.


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