NWCDN Members regularly post articles and summary judgements in workers’ compensations law in your state.
Select a state from the dropdown menu below to scroll through the state specific archives for updates and opinions on various workers’ compensation laws in your state.
Contact information for NWCDN members is also located on the state specific links in the event you have additional questions or your company is seeking a workers’ compensation lawyer in your state.
When you think of pirates of the 13th Century, images of fierce sword-wielding warriors engaged in bloody ship to ship sea battles immediately come to mind. It may shock you to know, that pirates actually had one of the earliest no-fault workers’ compensation systems. Each ship had a written compensation schedule where it was agreed that the loss of a limb would result in a lump sum payment of a pre-set number of pieces of eight. Once the agreement was signed, it was not negotiable. Therefore, despite their bloody nature, the pirates’ workers’ compensation system was not adversarial in any way.
The modern day workers’ compensation system, however, is exceedingly adversarial. By definition, the system is characterized by conflict or opposition. The word “adversarial” is synonymous with words such as “jaundiced”, “negative”, “unfriendly”, and “unsympathetic”. Such an antagonistic system often times results in delays to the injured employee and increased costs to the employers and insurers. Why and how has it come to this?
There is language in every state’s Workers’ Compensation Act that is open to interpretation by judges. Issues of causation and extent of disability are also typically litigated matters. Contributing to the process are harbored feelings by parties and their lawyers of bias, demonization, distrust, prejudice, and stigmatization. When you throw in the personalities and emotions of all involved, it creates an environment that would shiver even a pirate’s timbers.
On September 19, 2019 at 1:00 p.m. EST, a webinar entitled Adversarial Workers’ Compensation Systems; Survival and Success in a Contentious World will be co-hosted by the President of WorkersCompensation.com, Bob Wilson, and Judge David Langham. Joining as guests to this 10th installment of The Hot Seat webinar series will be Virginia Commissioner Wes Marshall and yours truly. Registration is free. You may register here.
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About the Author
This blog submission was prepared by Mike Fish, an attorney with Fish Nelson & Holden, LLC, a law firm dedicated to representing self-insured employers, insurance carriers, and third party administrators in all matters related to workers’ compensation. Fish Nelson & Holden is a member of the National Workers’ Compensation Defense Network. If you have any questions about this submission or Alabama workers’ compensation in general, please contact Fish by e-mailing him at mfish@fishnelson.com or by calling him directly at 205-332-1448.
A review of consent orders issued by the Commissioner of Workers’ Compensation since early 2019 indicates the DWC is monitoring and removing designated doctors who fail to perform under the requirements of the rules. A Medical Quality Review Panel (“MQRP”) audit was done to evaluate the medical necessity and appropriateness of additional testing or referral by designated doctors. At the conclusion of the audit, the DWC determined that, not only did the doctors unnecessarily make referrals to other providers or order unnecessary testing, they also engaged in other activities that either violated the rules or were considered substandard by the DWC. Specifically, the consent orders identify the following reasons for sanctioning the designated doctors:
The following designated doctors have either been removed from the DWC designated doctor list for a period of time ranging from 2 to 4 years or have been ordered to pay administrative penalties and complete DWC workshops and other additional training:
AL Jameson, D.C. removed for 2 years
Sandra E. Silmon, D.C. fined and training orderedAt the recent State Bar of Texas Advanced Workers’ Compensation Seminar, attorney Matt Lewis, reviewed the DWC Appeals Panel decisions from August of 2018 to July of 2019. Lewis noted that the vast majority of the Appeals Panel Decisions focused on correcting clerical errors or misstatements of evidence and facts in Administrative Law Judge Decisions. The decisions were remanded or rendered by the Appeals Panel in situations where ALJs: failed to make a determination on complete periods of disability; provided inconsistent determinations within the D&O; failed to make findings of facts and conclusions of law on all issues litigated; misstated fact despite stipulations to those facts; failed to allow a Carrier to get an RME after the ALJ ordered a new DD examination; and, adopted MMI/IR certifications that failed to rate the entire compensable injury or rated conditions that were not compensable.
In the months of July and August of 2019, the Appeals Panel wrote four decisions.
To Rate a Hernia, There Must be a Palpable Defect. In APD 191070, the ALJ adopted the designated doctor’s certification of MMI/IR, which included 1% for bilateral inguinal hernia using Class 1 in Table 7 of the AMA Guides. However, the designated doctor’s narrative report explained that Claimant’s hernia repair was holding well and he had no palpable defect or protrusion. The Appeals Panel noted that each class listed in Table 7 of the AMA Guides requires a palpable defect in the supporting structures of the abdominal wall to justify rating under that table. The case was remanded for the ALJ to instruct the DD to rate the compensable injury in accordance with the AMA Guides.
Injury While Walking Across a Public Street is Likely Not Compensable under the Access Doctrine. In APD 190929, the Appeals Panel discussed, among other things, whether an injury was compensable under the access doctrine where the claimant was walking across a public street when he was struck by a truck. Under the “coming and going” rule, an injury that occurs while an employee is going to or coming from work is not compensable. However, there are several exceptions to this general rule including the “access doctrine.” Under the “access doctrine,” an injury is compensable if the employer has evidenced an intention that the access route or area that should be used by employees in going to or from work is so closely related to the employer’s premises as to be fairly treated as part of them.
The claimant in this case was injured when he was struck by a truck while crossing a public street on foot. The ALJ determined the injury was compensable, but failed to identify under which of the four alternate theories advanced the ALJ relied to determine the injury was compensable. The Appeals Panel remanded to the ALJ for further development of the case, but cautioned that the Supreme Court has held that “no case has extended the ‘access exception’ out into the public streets where other members of the public are subject to the same hazard.”
ALJ Cannot Add Issue if it is Not Raised at the BRC or Actually Litigated. In APD 190915, the Appeals Panel reversed and struck an ALJ’s determination that the Carrier did not specifically contest compensability based on the claimant’s failure to timely file a claim for compensation within one year. The issue was not certified out of the BRC and neither party asked to add the issue at the CCH. In fact, the issue was never mentioned at the CCH. The ALJ added the issue after the CCH without notifying the parties he was doing so. The Appeals Panel held that the issue of the carrier’s waiver was not actually litigated and it was an abuse of discretion to add the issue.
Rebutting the Compensability Presumption in Firefighter Cancer Case. In APD 191065, the ALJ determined that a self-insured rebutted the presumption that a firefighter developed pancreatic and liver cancer during the course and scope of his employment. The self-insured showed that a risk factor, accident, hazard or other cause not associated with the firefighter’s work caused his cancer, relying on a doctor’s report. In testimony at the CCH, the doctor opined that the cancer was related to family history. The Appeals Panel disagreed with the ALJ that the presumption of compensability was rebutted by the self-insured.
The self-insured’s rebuttal evidence included the firefighter’s own testimony that his father had kidney cancer. However, no specific evidence was offered linking the father’s kidney cancer to a neuroendocrine tumor, which is one of the conditions with which the firefighter had been diagnosed. Moreover, the self-insured’s doctor did not identify the cause of the firefighter’s cancer, but rather, the doctor simply voiced his contention that the cancer was related to family history citing an absence of the cancer among those identified in the firefighter literature.
The Appeals Panel reversed and rendered a decision that the self-insured did not rebut the presumption. Following this decision, it appears that to rebut the presumption, the Appeal Panel may require some evidence of genetic testing to determine if the firefighter possesses any of the genetic syndromes which have been identified to cause pancreatic neuroendocrine tumors.
Copyright 2019, Stone Loughlin & Swanson, LLP
SB 1742, effective 09/01/19, amended Texas Labor Code Section 408.0043 and requires peer review, utilization review and independent review of health care services to injured employees to be performed by doctors of “the same or a similar specialty” as the requesting physician. It will be up to the DWC to explain, hopefully by administrative rule, what “similar” actually means.
Prior to the amendment, the statute required peer review, utilization review, independent review, designated doctor, required medical examination and medical quality review panel doctors who reviewed workers’ compensation cases to hold “a professional certification in a health care specialty appropriate to the type of health care that the injured employee is receiving.” The amendment now requires a specialty “match” the requestor for certain kinds of review. It remains to be seen how “similar specialty” will be defined by the DWC.
Copyright 2019,Stone Loughlin & Swanson, LLP
While limited workers’ compensation legislation was passed in the 2017 session, there were a few new items advanced out of the recent 86th Legislature. Prominent among this year’s new laws is SB 2551, which addressed workers’ compensation liability, payment and benefits relating to firefighter and emergency medical technicians suffering from cancer as a result of their job duties for claims filed on or after 6/10/19.
The DWC recently accepted comments on an informal working draft of rules designed to implemental SB 2551. The changes involve the amended process for claim notification, the carrier’s obligation to investigate when it receives notice of an injury for which a presumption may apply, and the assessment of administrative penalties and factors to be considered in determining sanctions for those violations.
Of particular note in this draft is the provision that, under certain circumstances, an insurance carrier is not required to comply with the 15-day deadline to initiate benefits payments or provide notice of refusal, and the steps a carrier must take to qualify for that exemption in those cases.
For more information see:https://www.tdi.texas.gov/wc/rules/documents/dr124sb2551m.pdf.
Copyright 2019,Stone Loughlin & Swanson, LLP
The State of Oklahoma filed suit against pharmaceutical manufacturers alleging their marketing, promotion and sales of opioid drugs in Oklahoma led to an opioid epidemic that constituted a violation of the state’s public nuisance law. On 8/26/19, an Oklahoma district judge ordered Johnson & Johnson to pay $572 million dollars to abate the public nuisance. In his 42 page judgment after a 33 day trial involving 42 witnesses and 874 exhibits, the judge laid out the history of the opioid crisis in Oklahoma and the rest of the country, and his conclusions that the defendants engaged in false and misleading marketing of their drugs in violation of Oklahoma’s public nuisance law.
Attorneys on both sides of the issue have been watching the Oklahoma case as several other states have sued drug manufacturers for their role in the nationwide crisis. The State of Texas, Bexar County, Harris County, the City of Houston, and McLennan County (to name a few) have all filed suit against Purdue Pharma and Johnson & Johnson, the defendants in the Oklahoma lawsuit.
A federal trial is scheduled to begin this fall in Ohio involving almost 2,000 cases brought by cities, counties, communities and tribal lands claiming the drug companies caused the epidemic. On the heels of the Oklahoma judgment, according to a Washington Post article published 08/27/19, Purdue Pharma, one of the common defendants in all of the pending opioid litigation, has offered to settle the federal suit for around $12 billion, including $3 billion in personal funds from the family who owns the company. The family would relinquish control of the company and declare bankruptcy as part of the deal. According to the article, the plaintiffs are considering the deal seriously in light of the fact that Purdue is likely headed to bankruptcy soon, regardless of the outcome of settlement negotiations.
Shortly after the Oklahoma judgment was entered, Johnson & Johnson attorneys announced their plan to appeal the judgment. It promises to be a long and drawn out process, but Round One of this test case goes to the plaintiffs.
- Copyright 2019, Stone Loughlin & Swanson, LLP
This practitioner is often asked two questions regarding workers’ compensation settlements in New Jersey: 1) Can we settle out of court? and 2) Can we get a termination agreement at the time of settlement?
There are a number of limitations on settlements in New Jersey that are different from the practice of law in other states. One has to do with the prohibition against out of court settlements. The employer, third party administrator or carrier may not reach an agreement with the injured worker to settle a workers’ compensation claim unless that claim is the subject of a claim petition properly filed and heard before a Judge of Compensation. An injured worker is not even eligible for an award of permanent partial disability until he or she files a claim petition through counsel.
Three sections of the New Jersey Workers’ Compensation Act make this clear: N.J.S.A. 34:15-22, 34:15-39, and 34:15-50. In all three sections, as a precondition to settling any claim of workers’ compensation, a claim petition must be filed in the Division of Workers’ Compensation, and only the Judge of Compensation can enter an order approving settlement or one of dismissal.
Another major distinction between New Jersey and other states has to do with waiver of workers’ compensation rights in other agreements. The statutes cited above make clear that the employer may not ask an injured worker to waive rights to workers’ compensation as part of another agreement, such as a separation agreement. There are many laws that can be waived in a valid separation agreement, such as rights under the ADA, FMLA, etc., but workers’ compensation is not one of them. These kinds of waivers are against public policy.
Similarly, it is fairly common in many states that an employer will get a signed letter of resignation at the time of the workers’ compensation settlement. There are both practical and legal reasons why this does not happen in New Jersey. First, most injured workers are back to work doing the very same job by the time the settlement occurs. That is a big practical difference from other states where workers remain out of work for years even for relatively modest injuries.
New Jersey is not a wage loss state but rather a functional loss state. Most of the injured workers in New Jersey who have formal claim petitions in the Division have already returned to work long before the settlement, either to their former job or a new job. In wage loss states like Pennsylvania, the injured worker may have been out of work for years by the time the case is settled. In states like Pennsylvania, the worker who has been away from work for years may agree to provide a letter of resignation for nominal consideration.
In New Jersey, going back to work – even the same job – does not detract from the ability of the injured worker to obtain a compensation award for permanent partial disability. Injured workers in New Jersey may receive both temporary disability benefits and an award of permanent partial disability as part of the same case. There is no requirement that an injured worker prove impairment of working capacity to obtain an award of permanent partial disability. All the injured worker must do is prove objective medical evidence of impairment as well as substantial impairment of major life activities.
Since the vast majority of injured workers are back to work in New Jersey at the time of settlement and doing the very same job as the one they did before their injury, seeking a resignation letter is fraught with legal peril. First, the employee is often an active working unit performing essential job functions. In that situation, there is seldom any legal basis to terminate someone who is doing his or her job satisfactorily. Second, many judges would view an attempt to terminate an injured worker as part of a workers’ compensation settlement as retaliatory or a violation of the New Jersey Law Against Discrimination. If the employee is able to perform the essential functions of the job, termination of employment as part of a settlement of a workers’ compensation claim would likely lead to immediate labor law litigation.
So can an employer ever get a resignation at the time of settlement? It can be done but it must be done through labor counsel, following all the rules that prevail in such agreements in New Jersey. Further, these employment releases are only done when the employee remains out of work for a very long time. The agreement between the parties must be negotiated for separate consideration, and the injured worker will almost certainly need his own labor counsel. There are many laws that such an agreement must cover to be effective, and any employment release must meet state and federal legal requirements.
If the parties do reach an agreement on termination of employment through respective labor counsel, that agreement will not be placed on the record in the New Jersey Division of Workers’ Compensation. Judges will not reference any separation agreement nor determine whether it is fair or just. The employment agreement is executed outside workers’ compensation court with both sides having retained labor counsel to advise them.
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John H. Geaney, Esq., is an Executive Committee Member and a Shareholder in Capehart Scatchard's Workers’ Compensation Group. Mr. Geaney concentrates his practice in the representation of employers, self-insured companies, third-party administrators, and insurance carriers in workers’ compensation, the Americans with Disabilities Act and Family and Medical Leave Act. Should you have any questions or would like more information, please contact Mr. Geaney at 856.914.2063 or by e‑mail at jgeaney@capehart.com.
The case of Kaur v. Garden State Fuels, Inc., A-2135-17T1 (App. Div. April 12, 2019) presents some interesting legal issues. The facts begin with the tragic death of Surinder Singh, who was shot and killed during the course of his employment at Woodbury Gulf LLC.
In 2014 Singh’s widow, Kirandeep Kaur, filed a dependency claim petition in workers’ compensation. The gas station was uninsured for workers’ compensation at the time of her husband’s death. Mr. Goyal and Mr. Saini were the sole members of the Woodbury Gulf LLC.
In 2015 Kaur sued Woodbury Gulf civilly alleging that the station’s negligence led to the death of her husband. She amended that suit in 2017 to add a claim against Mr. Goyal.
On March 28, 2016, petitioner settled her workers’ compensation dependency claim petition for $150,000. She said that she understood that the Section 20 settlement was final and that she could not return for further workers’ compensation benefits. Petitioner received mostly deferred payments from the two members of the LLC: $30,000 up front followed by $5,000 each month for 24 months. The Order recited that the settlement was not a complete and absolute surrender and release of any and all rights of petitioner’s dependents under Section 13. This was important because the petitioner and decedent had two young children.
The Judge of Compensation did not sign the 2016 order but waited until 2018 when all payments had been made. Counsel reappeared on April 13, 2018, and the Judge again commented that this Section 20 settlement did not contemplate a release of decedent’s dependents’ rights.
Meanwhile in her civil law suit, Kaur made some interesting arguments:
1. She argued that she could sue Woodbury civilly because the gas station’s insurance had lapsed. She contended that this was akin to an intentional wrong, thereby exempting her from the fundamental rule that neither an employee nor an employee’s dependents can sue the employer.
2. She also argued that payments under a Section 20 are not recognized as workers’ compensation payments for any purpose other than for insurance rating purposes, so a civil suit should be permitted.
The motion judge ruled for Woodbury LLC and its members, holding that the civil law suit was barred. Kaur appealed. The Appellate Division devoted a good deal of analysis to Section 20 settlements. It said, “A Section 20 settlement bars a subsequent lawsuit against the paying employer as it would be unfair to hold the employer liable for both common law damages and workers’ compensation liability,” citing Hawksby v. DePietro, 165 N.J. 58 (2000).
The Court also seemed to suggest that a Section 20 settlement amounts to an implied acknowledgement that a claimant’s disability is work related, citing the Sperling case for this concept. For these reasons the Appellate Division affirmed the ruling that petitioner and her children could not sue her husband’s employer or the members of the LLC.
As for the failure of Woodbury to maintain insurance for its own employees, the Court pointed out that this was potentially either a disorderly person offense or a fourth-degree crime, depending on whether the actions were willful. Nonetheless, the Court ruled, “Their failure to maintain insurance did not alter the effect of the Workers’ Compensation bar, especially since plaintiff took advantage of the Act’s statutory scheme to obtain benefits under the Section 20 settlement.”
Importantly, the Court confirmed that consent of the workers’ dependents must be obtained for a Section 20 settlement that purports to waive dependency benefits. In sum, the Court held that the two minor children were entitled to bring a dependency claim of their own against Woodbury Gulf and the members of the LLC. The Court cited the Kibble case for the proposition that “a Section 20 settlement between the employer and a claimant ‘cannot extinguish the rights of those who do not participate, or do not have the opportunity to participate in a settlement.’”
The case is helpful in understanding that it does not really matter whether the workers’ compensation claim is resolved under an order approving settlement with reopener rights or a Section 20: in either case, the claimant and his or her dependent cannot bring a civil action against the employer since the exclusive remedy is workers’ compensation.
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John H. Geaney, Esq., is an Executive Committee Member and a Shareholder in Capehart Scatchard's Workers’ Compensation Group. Mr. Geaney concentrates his practice in the representation of employers, self-insured companies, third-party administrators, and insurance carriers in workers’ compensation, the Americans with Disabilities Act and Family and Medical Leave Act. Should you have any questions or would like more information, please contact Mr. Geaney at 856.914.2063 or by e‑mail at jgeaney@capehart.com.
An independent medical examination can be requested at any reasonable time and place in the state for a variety of reasons: there may be an issue of causation, ability to work, second opinion on surgery, need for further treatment, or assessment of permanent partial disability. No matter what the purpose of the examination is, a well-reasoned IME is critical to the successful defense of workers’ compensation claims.
This blog focuses on the steps employers, carriers, third party administrators and lawyers should take as well as the mistakes to avoid in setting up IMEs.
Explain the nature of the claim to the IME physician.
Example: Employee files an occupational claim petition alleging physical labor from 2000 to January 30, 2019 caused knee pathology. The employer denies the claim petition. An IME is arranged. There is no explanation of the allegations of the claim to the IME physician. No letter is ever sent other than perhaps a check-off letter asking for guidance on “permanency” and “causation.” The injured worker tells the physician during the IME that on January 30, 2019 he felt pain in his left knee while walking at work. The employee has an MRI showing a tear. The doctor writes a report stating, “I find that the petitioner’s accident of January 30, 2019 caused his knee pathology and I recommend arthroscopic surgery.”
What went wrong? The claim was not for a specific accident! January 30, 2019 was just the last day of exposure when the pain was noticed or became intolerable. Occupational claim petitions are required to list a beginning and end date. This claim asserted that 19 years of physical labor caused the knee pathology, not walking at work one day (which is not a true accident). The doctor in this case did not know that the claim was denied, nor that this was truly an occupational claim and that the worker was never injured on any particular day.
Send the IME physician key information in the case:
As a general rule, the IME physician wants to read the claim petition to understand the formal allegations, as well as the answer of the respondent. The doctor wants to see all treating records including prior records that may be relevant. If there are answers to interrogatories, the doctor will want to see them as well because they often contain important information. If there is a recent and subsequent injury, whether work or non-work related, the IME doctor will want that information.
If you have a specific doctor or type of specialty you need for an IME, don’t call an IME group and ask for the next available IME date without mentioning the particular physician or specialty.
IME companies have dozens of physicians that they schedule for IMEs. Some are surgeons; some are not. If you want the earliest possible date, the company will find the physician whose calendar is open and assign you that doctor. That may or may not be the doctor or specialty you wanted. Some physicians are very busy and booked out for three months; others have fewer assignments. If you just want any orthopedic surgeon as soon as possible, but you do not want an occupational physician or physiatrist, then make that clear.
Make sure you have all the relevant records –including records of prior and subsequent accidents – before setting up the IME.
We all want cases to move quickly. The average New Jersey claim petition lasts 28 months, so understandably clients are concerned about moving files. However, rushing an IME is generally a mistake. The absence of critical records often costs the employer a great deal of money. The IME doctor can only give an opinion on the records he or she has. There may be prior records that will show that the condition at issue was already in existence a few months before the accident, or that there has been a subsequent non-work car accident which has significantly aggravated the work-related condition. The process of getting medical records takes time. It takes time to prepare and send HIPAAs to opposing counsel, who then send them to their clients to be returned to respondent counsel. Hospitals often delay sending records. The hospital may reject the medical authorization and demand a subpoena. But getting the prior or subsequent medical records may help clarify whether the claim is even work related, thereby avoiding costs of surgery and a large permanency award, with a potential reopener down the line. This practitioner has seen cases where the doctor is missing almost all the treating records and writes a report basically drawing no conclusions pending receipt of medical records. That creates a need for a second IME with double the cost.
When a case has high exposure or is likely to be tried, retain the most qualified expert.
Yes, it costs more to retain a board certified expert with a sub-specialty. But there are many high exposure cases in workers’ compensation, and the cost of not retaining a specialized expert is far greater than the extra $1,000 you may pay for a medical report from a highly qualified expert. When you have a case involving lung cancer, you should retain a board certified oncologist or pulmonologist. There are many internists who do such examinations but they may not have sat for or passed the board certification in pulmonology. The outcome of a case often depends on the credibility of competing experts. Judges always assess credibility of medical experts; they review their training and qualifications, and they consider the expertise of the IME physician when the experts flatly disagree on an issue in the case. This advice is also true in orthopedic cases. If the case involves an issue of whether a fusion surgery should be performed, respondent is far better off retaining an expert who performs fusions, rather than an expert who does not perform such surgery.
Find out early on if a translator is needed.
There are few things in workers’ compensation more frustrating than cancellation of an IME because the employee could not converse with the IME physician. Contact must be made early on with petitioner’s attorney to inquire whether the injured worker will need a translator and if so, what specific language will be needed.
Try to make a reminder call or send an email to petitioner’s attorney a few days before the IME.
This is not always possible to do, since everyone is so busy, but it pays off. Many times a letter is sent to a petitioner’s attorney two or three months before the exam date. When an exam is set up months in advance, there is a higher likelihood of a missed appointment. Communications fall apart or injured workers forget about the exam date. If possible, a follow-up call or email to counsel a few days before the exam may eliminate a potential missed appointment.
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John H. Geaney, Esq., is an Executive Committee Member and a Shareholder in Capehart Scatchard's Workers’ Compensation Group. Mr. Geaney concentrates his practice in the representation of employers, self-insured companies, third-party administrators, and insurance carriers in workers’ compensation, the Americans with Disabilities Act and Family and Medical Leave Act. Should you have any questions or would like more information, please contact Mr. Geaney at 856.914.2063 or by e‑mail at jgeaney@capehart.com.
Today marks 100 years since Governor Thomas Kilby signed bill 26-1 into law thereby creating what is now known as the Alabama Workers’ Compensation Act. Back then, it was known as the Alabama Workmen’s Compensation Act. The law later went into effect on January 1, 1920. Although there has been some recent controversy as to the constitutionality of the Act in its current state, it remains a better alternative to employees having to prove tort liability and tort liability exposure for the employer. As the Honorable E.R. Mills so adeptly stated in his Singletary v. Mangham Construction,
418 So.2d 1138 (Fla. 1st DCA, 1982) opinion, “Workers' compensation is a very important field of the law, if not the most important. It touches more lives than any other field of the law. It involves the payments of huge sums of money. The welfare of human beings, the success of business, and the pocketbooks of consumers are affected daily by it.”
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About the Author
This blog submission was prepared by Mike Fish, an attorney with Fish Nelson & Holden, LLC, a law firm dedicated to representing self-insured employers, insurance carriers, and third party administrators in all matters related to workers’ compensation. Fish Nelson & Holden is a member of the National Workers’ Compensation Defense Network. If you have any questions about this submission or Alabama workers’ compensation in general, please contact Fish by e-mailing him at mfish@fishnelson.com or by calling him directly at 205-332-1448.