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Michigan S. Ct. Limits Ability of Out-of-State Workers to Collect Benefits From Michigan Employers

The Michigan Supreme Court, in a 4-1-2 decision in Karaczewski v Farbman Stein & Co., (Case No. 129825, May 23, 2007), overruled Boyd v W G Wade Shows, 443 Mich 515; 505 NW2d 544 (1993), in holding that ""a Florida resident who was injured in a Florida workplace accident may [not] recover workers' compensation benefits in Michigan merely because he was hired in Michigan.” The majority opinion was written by Justice Corrigan. The four member majority applied the ruling retroactively. Justice Weaver concurred in overruling Wade, but dissented on applying the ruling retroactively. Justices Kelly and Cavanaugh dissented. This decision gives relief to Michigan employers with out-of-state employees whose only connection with Michigan was the contract of hire. 5-24-07

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