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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ3250254 (ANA 0403409)
Regular
Jul 22, 2013

TROY SADOWSKI vs. CINCINNATI BENGALS

The Workers' Compensation Appeals Board affirmed a WCJ's decision finding no California jurisdiction over a professional football player's claim. The player was hired and covered by Ohio workers' compensation, and his presence in California was temporary for work. This temporary presence, combined with Ohio's reciprocal extraterritorial provisions, exempted the parties from California's workers' compensation law per Labor Code section 3600.5(b). The Board relied on its en banc decision in *Carroll v. Cincinnati Bengals* which established these exemption criteria.

Subject Matter JurisdictionLabor Code Section 3600.5(b)Temporary Presence ExceptionExtraterritorial ProvisionsOhio Workers' Compensation LawCincinnati BengalsProfessional Football PlayerCumulative Industrial InjuryReconsiderationEn Banc Decision
References
3
Case No. MISSING
Regular Panel Decision

Mordkofsky v. V.C.V. Development Corp.

Plaintiff Norman J. Mordkofsky, a contract-vendee, sustained injuries when a deck at his custom-built home construction site collapsed. He sued defendant V.C.V. Development Corp., alleging negligence and violations of Labor Law §§ 200 and 241. While the Supreme Court dismissed the Labor Law claim, the Appellate Division reinstated it, broadening the protection of these statutes to anyone lawfully frequenting a construction site. However, the higher court reversed the Appellate Division's decision, clarifying that Labor Law §§ 200 and 241 are primarily intended to protect employees and workers, not contract-vendees or the general public. The court concluded that Mordkofsky did not fall within the protected class as he was neither an employee nor hired to work at the site.

Labor Law §§ 200 and 241Construction Site InjuryContract-VendeeEmployee ProtectionStatutory InterpretationScope of Labor LawAppellate ReviewSafe Place to WorkWorkers' RightsPersonal Injury
References
14
Case No. 2025 NYSlipOp 07110
Regular Panel Decision
Dec 18, 2025

People v. R.V.

The Appellate Division, First Department, affirmed an order by the Supreme Court, New York County, which granted the defendant R.V.'s CPL 210.40 motion to dismiss the indictment in furtherance of justice. The court found that the Supreme Court providently exercised its discretion, noting that R.V. purchased a false Covid-19 vaccination card to maintain employment as an essential worker during the pandemic. The decision highlighted that R.V.'s actions caused no specific or societal harm, supporting the dismissal in the interest of justice.

Indictment DismissalInterest of JusticeCPL 210.40COVID-19 Vaccination CardEssential WorkerAppellate ReviewDiscretionary DismissalLack of Harm
References
2
Case No. MISSING
Regular Panel Decision

Wolfgang Doerr v. Daniel Goldsmith / Cheryl Dobinski v. George O. Lockhart

This concurring opinion by Justice Abdus-Salaam addresses two cases, Doerr v Goldsmith and Dobinski v Lockhart, concerning negligence claims against domestic animal owners for injuries caused by their pets. The opinion reaffirms the long-standing "vicious propensities" rule established in Bard v Jahnke, which limits liability solely to strict liability when an owner knew or should have known of an animal's dangerous tendencies. Justice Abdus-Salaam rejects arguments to extend the Hastings v Sauve precedent, which allowed negligence claims for farm animals straying from property, to domestic pets. The opinion also refutes the distinction between an owner's active control and passive failure to restrain, emphasizing that a pet's volitional behavior is the ultimate cause of harm. Consequently, Justice Abdus-Salaam votes to dismiss the negligence claims in both cases and affirms the dismissal of Dobinski's strict liability claim due to insufficient evidence of the owners' prior knowledge of their dogs' propensities.

Animal LawNegligenceStrict LiabilityDomestic AnimalsFarm AnimalsVicious Propensity RuleDuty of CareSummary JudgmentAppellate ReviewCourt of Appeals
References
20
Case No. MISSING
Regular Panel Decision

People v. Johnson

This opinion from the Court of Appeals addresses the critical issue of juror impartiality in criminal trials, specifically concerning challenges for cause when prospective jurors express doubts about their fairness. The Court consolidated three cases: People v. Johnson and People v. Sharper, both robbery cases involving juror bias towards police testimony, and People v. Reyes, a drug sale case where jurors harbored biases related to drug abuse and a defendant's prior convictions. The Court reiterated that when potential jurors reveal a state of mind likely to preclude impartial service, they must provide unequivocal assurance of their ability to set aside any bias and render a verdict based solely on evidence. Concluding that the trial judges in these cases failed to obtain such unequivocal assurances, the Court affirmed the Appellate Division's reversal of convictions in Johnson and Sharper, and reversed the Appellate Division's affirmation of conviction in Reyes, ordering a new trial. This decision underscores the fundamental constitutional right to an impartial jury and clarifies the standard for excusing biased jurors under CPL 270.20.

Jury SelectionVoir DireJuror ImpartialityChallenge for CauseUnequivocal AssurancePolice Testimony BiasDrug Offense BiasPrior Conviction BiasCriminal Procedure LawAppellate Review
References
31
Case No. ADJ2295331 (ANA 0397551)
En Banc
Jun 18, 2013

Wesley Carroll vs. Cincinnati Bengals, New Orleans Saints, Louisiana Workers' Compensation Corporation, Travelers Insurance

The Appeals Board held that under Labor Code § 3600.5(b), an employee hired outside California is exempt from the state's workers' compensation laws if they are temporarily in the state for work, the employer provides coverage from another state, and that state has reciprocal exemption provisions, leading to the dismissal of the Cincinnati Bengals from the case.

WCABEn BancReconsiderationLabor Code § 3600.5(b)ExemptionExtraterritorial ProvisionsOhio Workers' CompensationSelf-Insured EmployerTemporary EmploymentCumulative Injury
References
51
Case No. ADJ2295331 (ANA 0397551)
Significant
Jun 18, 2013

Wesley Carroll vs. Cincinnati Bengals, New Orleans Saints, Louisiana Workers' Compensation Corporation, Travelers Insurance

The Appeals Board held that an out-of-state employee and employer are exempt from California's workers' compensation system under Labor Code section 3600.5(b) when the employee is only temporarily in California, the employer provides coverage under another state's similar laws, and that state offers reciprocal exemption to California employers. Consequently, the Cincinnati Bengals were dismissed as a defendant.

Workers' Compensation Appeals BoardEn Banc DecisionLabor Code § 3600.5(b)Extraterritorial CoverageTemporary EmploymentSelf-Insured EmployerOhio Workers' Compensation LawReciprocityCumulative InjuryHire Outside of California
References
47
Case No. CV-23-1524
Regular Panel Decision
Jun 27, 2024

In the Matter of the Claim of John Carroll

John T. Carroll, a police officer, sustained back and knee injuries in 2009, leading to spinal surgery and restricted administrative duties. He opted for normal service retirement in May 2020, subsequently claiming involuntary retirement due to worsening back pain. A Workers' Compensation Law Judge initially found his retirement involuntary, but the Workers' Compensation Board modified this, ruling that Carroll had voluntarily withdrawn from the labor market and was not entitled to postretirement wage loss benefits, citing that his disability did not prevent him from performing accommodated light duty. The Appellate Division affirmed the Board's decision, concluding that substantial evidence supported the finding that Carroll's work-related injuries did not cause or contribute to his decision to retire.

Voluntary Withdrawal from Labor MarketPostretirement Wage Loss BenefitsDisability BenefitsMedical Opinion ConflictCredibility AssessmentSubstantial Evidence ReviewAppellate DivisionBack Injury ClaimPolice EmploymentRestricted Duty Accommodation
References
10
Case No. MISSING
Regular Panel Decision

MATTER OF THEROUX v. Reilly

The New York State Court of Appeals addressed whether eligibility for benefits under General Municipal Law § 207-c requires a 'heightened risk' standard for injuries sustained by municipal employees in law enforcement duties. The court concluded that section 207-c does not mandate such a standard, interpreting 'duties' to encompass the full range of a covered employee's job responsibilities. It clarified that eligibility only necessitates demonstrating a 'direct causal relationship between job duties and the resulting illness or injury.' Consequently, the Court reversed the Appellate Division orders in three consolidated cases (Theroux v Reilly, Wagman v Kapica, and James v County of Yates Sheriff’s Dept.) that had erroneously applied the 'heightened risk' standard, reinstating Supreme Court orders in two and remitting one for further proceedings.

Workers' CompensationGeneral Municipal LawPolice OfficersFirefightersDisability BenefitsStatutory InterpretationAppellate ReviewCausal RelationshipJob DutiesPublic Safety Officers
References
20
Case No. MISSING
Regular Panel Decision

Bartoo v. Buell

This case addresses whether the homeowner exemption of Labor Law § 240 (1) and § 241 (6) applies to structures used for both residential and commercial purposes. The court applies a "site and purpose" test to determine applicability. In Bartoo v Buell, the repair of a barn roof, used for both personal storage and commercial golf cart storage, was deemed primarily residential, thus granting the owner exemption. In Anderson v Flanagan, the addition of a bedroom to a home also operating a daycare center was found to be directly related to residential use, exempting the owner from liability. The Court concluded that owners of one- or two-family dwellings who do not direct or control the work are shielded by the homeowner exemption when the work directly relates to the residential use of the home, even if it also serves a commercial purpose.

Homeowner ExemptionLabor LawDual-Use PropertyResidential UseCommercial UseStrict LiabilitySite and Purpose TestScaffold CollapseRoof RepairBedroom Addition
References
7
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