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Case Law Database

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

Case No. MISSING
Regular Panel Decision

In re the Claim of Bonilla

Claimant, a postal worker, was arrested for threatening suicide and subsequently required to undergo a psychiatric evaluation by releasing his medical records to determine his fitness for duty. He refused to release these records, which prevented the completion of the psychiatric examination and ultimately led to him not being permitted to return to work. The Unemployment Insurance Appeal Board then disqualified him from receiving unemployment insurance benefits, ruling that he voluntarily left his employment without good cause. This decision was based on the premise that a claimant who fails to take a reasonably required step as a prerequisite to continued employment is deemed to have voluntarily left their job without good cause. The appellate court affirmed the Board's determination, finding it supported by substantial evidence in the record.

Voluntary separationUnemployment benefitsGood cause for leaving employmentMedical records releaseFitness for dutyPsychiatric evaluationPostal workerDisqualification from benefitsSubstantial evidence
References
1
Case No. MISSING
Regular Panel Decision

Boots v. Stanley Black & Decker, Inc.

Peter and Cindy Boots filed a products liability action against Stanley Black & Decker, Inc., alleging injury to Peter Boots from a defective utility knife. Defendant moved for summary judgment, asserting no manufacturing defect, no design defect as the proximate cause, substantial modification of the product, and that Plaintiff's own negligence was the sole proximate cause. The court denied the motion for summary judgment on the manufacturing defect claim, finding the plaintiff's expert report admissible. It also denied summary judgment on the design defect claim due to misleading design, and rejected the substantial modification argument. Finally, the court denied the proximate cause argument, as it was not established that Plaintiff's actions were the *sole* cause of injury.

Products LiabilitySummary JudgmentManufacturing DefectDesign DefectProximate CauseExpert WitnessUtility KnifeStrict LiabilityProduct SafetyFederal Civil Procedure
References
38
Case No. ADJ9190661 ADJ9735754 ADJ9735757
Regular
Nov 20, 2015

WILLIAM CRONIN vs. HONEYWELL INTERNATIONAL INC., XL SPECIALTY INSURANCE COMPANY as administered by MATRIX ABSENCE MANAGEMENT, INC.

The Workers' Compensation Appeals Board granted reconsideration and found that William Cronin sustained a psychiatric industrial injury arising out of and in the course of employment with Honeywell International. The Board affirmed that actual employment events were predominant causes of the injury. Defendant failed to prove the injury was substantially caused by a lawful, nondiscriminatory, good faith personnel action, as the events cited did not constitute a substantial cause. The previous award was rescinded and substituted with this finding, deferring other issues.

Workers' Compensation Appeals BoardIndustrial InjuryPsychiatric InjuryActual Events of EmploymentPredominant CauseGood Faith Personnel ActionDue ProcessAdmissible EvidenceAgreed Medical ExaminerTreating Physician Reports
References
7
Case No. MISSING
Regular Panel Decision
Oct 25, 2010

Viti v. Guardian Life Insurance Co. of America

Joseph Viti, suffering from post-traumatic stress due to 9/11, sued The Guardian Life Insurance Company of America under ERISA after his disability benefits claim was denied. Guardian denied the claim and Viti failed to appeal within the six-month administrative period. Viti also applied for and received Social Security disability benefits. The court granted Guardian's motion to dismiss the Third and Fourth Causes of Action, which concerned failure to provide documentation, concluding Guardian was not the proper defendant for those claims. The court denied without prejudice both parties' motions regarding the First and Second Causes of Action, which focused on the timeliness of Viti's lawsuit and the applicability of equitable tolling to contractual limitation periods, referring this matter to Magistrate Judge Dolinger for a hearing on equitable tolling.

ERISADisability BenefitsEquitable TollingStatute of LimitationsMental ImpairmentAdministrative RemediesContractual LimitationsSummary JudgmentMotion to DismissFiduciary Duty
References
41
Case No. ADJ10384186 MF ADJ10404193
Regular
Mar 25, 2019

SCOTT MITCHELL vs. DENIHANA, ZURICH NORTH AMERICA

This case concerns a claim for psychiatric injury where the applicant, Scott Mitchell, alleged actual employment events were the predominant cause. The Workers' Compensation Appeals Board denied the defendant's petition for reconsideration. The Board affirmed the WCJ's findings, giving great weight to credibility determinations and finding no substantial evidence to reject them. Crucially, the Board concluded the injury was not substantially caused by lawful, nondiscriminatory, good faith personnel actions, as required by Labor Code section 3208.3. The Board relied on the agreed medical examiner's opinion that employment stress predominantly caused the aggravation of the applicant's pre-existing condition.

Labor Code 3208.3predominant causepsychiatric injurygood faith personnel actionsubstantial causecredibility determinationsaggravation of pre-existing conditionagreed medical examinercumulative traumaanxiety disorder not otherwise specified
References
6
Case No. MISSING
Regular Panel Decision

State Division of Human Rights v. Dunlop Tire & Rubber Corp.

This proceeding sought to annul a determination of no probable cause by the New York State Division of Human Rights, affirmed by the State Human Rights Appeal Board. The petitioner alleged racial discrimination by Dunlop Tire and Rubber Corporation and United Rubber Workers, Local No. 135. The court ruled that a prior Federal District Court dismissal of the petitioner's identical discrimination claim against the same defendants, under federal law, barred the instant state action based on the doctrine of res judicata. The elements required for establishing a prima facie case in both federal and state actions were deemed nearly identical. Additionally, the court found substantial evidence supported the New York State Human Rights Appeal Board's determination.

Human Rights LawRacial DiscriminationEmployment DiscriminationRes JudicataExecutive LawPrior AdjudicationState Division of Human RightsHuman Rights Appeal BoardNew YorkFederal Precedent
References
6
Case No. MON 0342844
Regular
Aug 20, 2007

DANNY HOPKINS vs. MCMAHAN'S FURNITURE STORES, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration of a decision that denied a psychiatric injury claim. The Board found the original judge did not properly apply the *Rolda v. Pitney Bowes* analysis to determine if a lawful personnel action was the substantial cause of the injury. The case is returned to the trial level for further analysis under *Rolda* and to allow for further development of the medical record, specifically regarding whether personnel actions were a substantial cause of the alleged injury.

Workers' Compensation Appeals BoardPsychiatric injuryLawful personnel actionRolda v. Pitney BowesInc.Labor Code section 3208.3Good faithNon-discriminatoryDemotionPredominant cause
References
3
Case No. ADJ7068660
Regular
Sep 20, 2011

LISA POLONSKY-BRITT vs. YUBA CITY UNIFIED SCHOOL DISTRICT

This case involves a teacher claiming a compensable psychiatric injury. The Workers' Compensation Appeals Board (WCAB) granted reconsideration and rescinded the prior award, finding the administrative law judge's (WCJ) decision lacked substantial medical evidence and failed to clearly address key legal issues. Specifically, the WCAB requires further development of the record to determine if actual employment events predominated as causes of the injury and if the injury was substantially caused by lawful, nondiscriminatory, good-faith personnel actions. The case is remanded for a new decision after the record is further developed.

Labor Code section 3208.3(b)(1)Labor Code section 3208.3(h)psychiatric injurypredominant causationlawful nondiscriminatory good faith personnel actionactual events of employmentmedical evidencesubstantial evidenceRolda v. Pitney BowesLarch v. Contra Costa County
References
11
Case No. ADJ6988363
Regular
Jun 11, 2013

CATHERINE BLUTCHER vs. WELLS FARGO BANK; SPECIALTY RISK

The Workers' Compensation Appeals Board denied Wells Fargo's petition for reconsideration of an award finding Catherine Blutcher sustained industrial injury to her psyche, internal system, and sleep disorder. The defendant argued the award was unsupported by substantial medical evidence and failed to adequately consider good faith personnel actions as a cause of injury. However, the Board found the defendant failed to meet its burden of proof to establish personnel actions as a substantial cause and that those actions were taken in good faith. Given the defendant's insufficient evidence on this affirmative defense, reconsideration was denied.

Workers' Compensation Appeals BoardIndustrial InjuryPsyche InjurySleep DisorderTemporary DisabilityPermanent DisabilitySubstantial Medical EvidenceGood Faith Personnel ActionBurden of ProofAffirmative Defense
References
2
Case No. MISSING
Regular Panel Decision

White v. County of Cortland

The case addresses whether a corrections officer must prove that job duties caused or contributed to a disability in a 'substantial degree' to qualify for General Municipal Law § 207-c benefits. The petitioner, a corrections officer, suffered work-related heart problems. The County denied his claim, citing a lack of 'substantial degree' of causation. The Supreme Court and Appellate Division found this to be an error of law, which was affirmed by the Court of Appeals. The Court held that section 207-c only requires a direct causal relationship, and preexisting conditions do not bar recovery if job duties were a direct cause.

Disability BenefitsCorrections OfficerHeart ConditionWork-Related InjuryCausal LinkStandard of ProofGeneral Municipal LawPreexisting ConditionAppellate ReviewNew York Law
References
8
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