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Insights
Court Case Update: Looking Back at 2025
Court Case Update: Looking Back at 2025
NCCI Page Content Two
InsightsLegal
 
 
By Annializ Lima Hevia and Adam LevellFebruary 16, 2026
 
​
Page Content

Since first published in 2018, NCCI’s Court Case Update has provided stakeholders with important and timely information on relevant workers compensation (WC) decisions that have impacted and shaped the system, reporting on over 300 cases to date.

In 2025, NCCI’s Legal Team monitored and reported on court decisions that considered familiar topics such as exclusive remedy, COVID-19, first responder presumptions, marijuana, and other specific state developments.

This report groups, by topic or region, all cases reported in 2025.

Exclusive remedy—providing immunity to employers from employee tort suits for work-related injuries covered by WC—has been a closely watched topic among WC stakeholders for several years. In 2025, we reported on decisions addressing applicability and exceptions to exclusive remedy.... view more

  • Illinois—Exclusive Remedy Under the Occupational Diseases Act, Martin v. Goodrich Corp. (Supreme Court of Illinois)
  • Maryland—Applicability of Exclusive Remedy to Lawsuit Brought by a Nondependent, Ledford v. Jenway Contracting, Inc. (Supreme Court of Maryland)
  • Washington—Intentional Injury Exception, Cockrum v. C.H. Murphy/Clark-Ullman, Inc. (Supreme Court of Washington)
... view less

With the onset of the COVID-19 pandemic in 2020, NCCI began monitoring COVID-19 cases that could have implications for the WC system. The cases reported on to date, including in 2025, have dealt with issues surrounding compensability from the alleged contraction of COVID-19 at work, or the application of exclusive remedy where employees contract COVID-19 and sue their employers in tort.... view more

  • Iowa—Exclusive Remedy Defense for Coworkers and Employers, Mehmedovic v. Tyson Foods, Inc. (Iowa Supreme Court)
  • New York—Compensability for Emotional Stress Injuries From Exposure to COVID-19, In the Matter of the Claim of Kimberly McLaurin v. New York City Transit Authority (New York Court of Appeals)
  • West Virginia—COVID-19 as Occupational Disease, Foster v. Primecare Medical of West Virginia, Inc. (Supreme Court of Appeals of West Virginia)
... view less

In the last decade, many states have enacted laws that create WC presumptions that certain injuries or diseases suffered by first responders arise in the course and scope of employment. In 2025, NCCI reported on the following cases that considered issues surrounding the application of first responder presumption laws.... view more

  • Arizona—Applicability of First Responder Cancer Presumption Statute, Krol v. The Industrial Commission of Arizona (The Supreme Court of Arizona)
  • Nevada—First Responder Presumption and Predisposing Factors, CCMSI v. Odell (Court of Appeals of Nevada)
... view less

Marijuana legalization at the state and federal levels, and the potential implications for WC, has been a hot topic for several years. Considerations related to legalization of marijuana are likely to be ongoing in 2026 as stakeholders monitor whether the federal government will move forward with the reclassification of marijuana from schedule I to schedule III of the Controlled Substances Act. In 2025, NCCI reported on an appellate court decision addressing the issue of WC reimbursement for CBD oil.... view more

  • Pennsylvania—CBD Oil Reimbursement, Schmidt v. Schmidt, Kirifides and Rassias, PC (Supreme Court of Pennsylvania)
... view less

This year, courts have reviewed questions related to attorney fees in WC cases. Some of these cases have considered the application of attorney fee statutes and their constitutionality.... view more

  • Alabama—Constitutional Challenge to Attorney Fee Cap, Carter-Shepherd v. Royal Furniture Co. (Alabama Court of Civil Appeals)
  • Maryland—Attorney Fees Lien, Zukowski v. Anne Arundel County (Supreme Court of Maryland)
  • New Mexico—Constitutional Challenge to Attorney Fees Statute, Pena v. State of New Mexico (Supreme Court of New Mexico)
  • New Mexico—Meaning of “Single Accidental Injury” When Calculating Attorney Fees, Hanrahan v. State of New Mexico (Supreme Court of New Mexico)
... view less

Across the states, courts remained engaged in cases that could impact the WC system and its stakeholders. These cases addressed issues such as benefit calculations, jurisdictional and procedural requirements, and payments to medical providers, among others.... view more

Northeastern Zone Cases

  • Connecticut—Discretion to Award Temporary Partial Incapacity Benefits, Gardner v. Dept. of Mental Health & Addiction Services (Supreme Court of Connecticut)
  • Pennsylvania—Recovering Overpayments From Medical Providers, Pioneer Construction Co. v. Insight Pharmaceuticals, LLC (Commonwealth Court of Pennsylvania)

Southeastern Zone Cases

 
  • Florida—Calculation of a WC Insurer’s Lien Amount, Liberty Mutual Insurance Co. v. Lee (Sixth District Court of Appeal of Florida)
  • Florida—Requirement to Seek Initial Relief Within the WC System, Steak ‘N Shake, Inc. v. Spears (Fifth District Court of Appeal of Florida)
  • Florida—Tolling the Statute of Limitations, Murphy v. Polk County Board of County Commissioners (First District Court of Appeal of Florida)
  • Florida—Admissibility of Expert Medical Adviser Opinions in WC Proceedings, Sedgwick Claims Management Services v. Thompson (First District Court of Appeal of Florida)

Midwestern Zone Cases

 
  • Iowa—Calculation of Benefits, Den Hartog Industries v. Dungan (Iowa Supreme Court)
  • Illinois—Medical Provider Not a Third-Party Beneficiary Under WC Settlement, Midwest Neurosurgeons v. F.W. Electric, Inc. (Appellate Court of Illinois, Fifth District)
  • Minnesota—Standard to Rebut Presumption of Retirement, Simonson v. Douglas County (Supreme Court of Minnesota)
  • Missouri—Liability of Second Injury Fund for Occupational Diseases, Treasurer of the State of Missouri v. Penney (Supreme Court of Missouri)

Western Zone Cases

 
  • California—Jurisdiction of the Workers’ Compensation Appeals Board Over Medical Necessity Determinations Disputes, Illinois Midwest Insurance Agency LLC v. WCAB (California Court of Appeals, Second District)
  • Hawaii—Rebutting the Presumption of Compensability, Lane v. Avis Budget Group, Inc.​ (Supreme Court of Hawaii)
  • Texas—Jurisdiction of the Division of Workers’ Compensation, University of Texas Rio Grande Valley v. Oteka (Supreme Court of Texas)
... view less

For more information on other cases monitored by NCCI's Legal Division, visit previous Court Case Updates and Court Case Insights under the Legal section of INSIGHTS on ncci.com.

​This article is provided solely as a reference tool to be used for informational purposes only. The information in this article shall not be construed or interpreted as providing legal or any other advice. Use of this article for any purpose other than as set forth herein is strictly prohibited.

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