Tag Archives: preemption

U.S. v. Washington: A rock, paper, scissors theory of federal preemption of workers’ comp. laws?

Posted on July 10, 2022 by Jon Rehm

Summary: When it comes to the interaction of federal law and workers’ compensation, federal laws invoking national security are the rock that crushes state law scissors, but federal laws regulating the domestic economy more are more like paper which cut get by scissors.

The Supreme Court stuck to intergovernmental immunity and stuck it to ill workers at the Hanford nuclear site in eastern Washington state.

In a 9-0 decision written by now retired Justice Stephen Breyer the court held in United States v. Washington, that Washington state could not enact a presumption of compensability under their state workers’ compensation act for workers made ill at the Hanford nuclear site. The court ruled that the presumption unlawfully discriminated against the federal government.

For 30 years the Department of Defense and Department of Energy produced plutonium for nuclear weapons at the Hanford site. The state of Washington passed legislation to make it easier for workers at that site to collect workers’ compensation benefits under their state law. The federal government challenged the law. Ultimately the court relied on the landmark case of McCulloch v. Maryland to hold that Washington’s law impermissibly discriminated against the federal government.

A decision of limited impact?

Justice Breyer’s opinion included no discussion of the merits of presumptions in workers’ compensation or the substance of workers’ compensation laws at all. I was somewhat concerned about where such discussion could lead. The United States Supreme Court had addressed workplace injuries cases involving nuclear plants in the Goodyear Atomic and Silkwood cases.

In both cases the court had rejected arguments from employers that certain workers’ compensation laws and tort laws were impermissible state regulations of an industry that was the regulatory responsibility of the federal government. But there were dissents in both Silkwood and General Atomics that would imply presumptions of compensability would be impermissible burdens on the federal government Fortunately, for worker-advocates, those dissenting opinions weren’t addressed by the court – even in a dissenting opinion.

An outlier decision?

I believe United States v. Washington is an outlier when it comes to the interaction of workers’ compensation laws and federal laws. Recently, the court declined to hear a Minnesota case that would have resolved the issue of whether states can require insurers to pay for medical marijuana. Marijuana is illegal under federal law and many states believe that law preempts state’s from requiring it to be covered under workers’ compensation laws.

Last year the court also declined to resolve a conflict between states and federal circuits as to whether the federal Airline Deregulation Act (ADA) preempted state laws requiring air ambulances charges to be paid at discounted rates under state workers’ compensation laws. The court also declined to hear challenge under the ADA from airlines against a Washington state law requiring paid leave for airline workers.

So why did the Supreme Court take up the Hanford case? I believe because of the national security implications of the case.

Federal supremacy and national security

Though Justice Breyer didn’t expressly mention national security in his opinion in United States v. Washington, the federal government clearly alluded to it in their brief. The federal government brought up Hanford’s role in the development of the atomic bomb during World War II.

Interestingly enough, in his last reported decision as a Supreme Court justice, Breyer penned the majority opinion in Torres v. Texas Department of Public Safety. In that case, a 5-4 majority held that states did not have sovereign immunity from private suits under the Uniformed Services Employment and Reemployment Rights Act (USERRA).

In Torres, Breyer wrote that the authority of Congress to build and maintain the armed forces under Article I, Sec. 10 of the Constitution overrode state sovereign immunity when it comes to suits against states under USERRA.

Though Torres and United States v. Washington lead to opposite outcomes for the employees involved in the case, they both demonstrated how the “rock” of national security beats the “scissors” of state sovereignty when it comes to the Supremacy Clause. Recent Supreme Court decisions relating to the interaction between workers’ compensation law and federal law regulating the domestic economy, show that those federal interests are more like “paper” which gets cut by scissors.

Is it better that SCOTUS punted on air ambulance cases

Posted on May 24, 2021 by Jon Rehm

The Supreme Court refused to hear an appeal from a Texas Supreme Court decision that allowed the State of Texas to regulate air ambulance charges in workers’ compensation cases.

The Supreme Court’s refusal to hear the case leaves in place a patchwork of state and federal court opinions about whether the Federal Aviation Act pre-empts state workers compensation laws that limit medical expenses for air ambulances.

Air ambulances and federal pre-emption is a dry and often esoteric, maybe even boring topic. But as Jon Gelman pointed out in his post on the decision, the right to regulate medical expense in workers’ compensation case helps states manage the cost of workers’ compensation. As I’ve pointed out at near ad nauseam, workers’ compensation laws are state-based laws. So, that’s why the air ambulance pre-emption issue matters to workers compensation.

So, what do I think of the Supreme Court’s decision to punt on the issue? Bluntly, I’m kind of relieved. I base my feelings on my big picture views of the Supreme Court and my very narrow interests in Nebraska workers compensation laws.

Do you really want Amy Coney Barrett and friends making decisions about workers comp.?

Well, do you?

From an academic perspective, the Texas Supreme Court decision on workers compensation and air ambulance billing is interesting. It’s really a discussion about the nature of workers’ compensation. Is it primarily an insurance program or is it primarily a law that regulates the relationship between employee and employer? My fear was that the current Supreme Court could pick up on any of the threads within the Texas case and make the law worse for injured workers.

Workers compensation as a law regulating the relationship between labor and management

So, if workers compensation is law that regulates the workplace, the dissent in the Texas decision held that air ambulances charges would be pre-empted. That would be a bad outcome for workers on air ambulance charges. It could also open the door for pre-emption on other issues to the detriment of employees.

Workers compensation as a law regulating insurance

The concurring opinion in the Texas held that their state’s regulation of air ambulance charges in workers’ compensation cases was not pre-empted because workers compensation is a law regulating insurance. Under the federal McCarran-Ferguson Act those laws are state laws and not subject to pre-emption. At least two trial Judges in the Nebraska Workers Compensation Court take this approach. Since the Supreme Court hasn’t weighed in on the issue, I can take this approach on air ambulance charges for the benefit of my clients in Nebraska.

But the Texas court also held that air ambulance charges weren’t pre-empted based on an originalist view of federalism. The Texas opinion starts out about states retaining some sovereignty when entering into the Union. In my view this language seems real overwrought. If I was a law student reading that opinion today, I might put a note like “Sir, this is a Wendy’s” by that passage.

Some plaintiff’s lawyers will go down the state’s rights rabbit hole. But I don’t like the state’s rights approach because it gives states the rights to implement lousy workers compensation laws. Texas is a model for how the state’s rights approach fails workers.

McCarrran-Ferguson: State’s rights lite?

McCarran-Ferguson is a more pragmatic argument against workers compensation pre-emption. But McCarran Ferguson is based on some dubious legal fiction. McCarran-Ferguson was passed to more or less repeal the Southeastern Underwriters case. That case held that insurance was interstate commerce.

Now the notion that insurance is interstate commerce would seem obvious to most people, but insurance wasn’t held to be commerce during much of the Lochner era. The Roberts court also seemed to question whether insurance was interstate commerce when they upheld the Affordable Care Act in 2012.

My other problem with McCarran-Ferguson is that it limits how we think about workers’ compensation. It locks judges and lawyers into adopting a legal fiction in order to give workers a fair outcome in workers compensation cases regarding air ambulance charges and other issues where federal laws could undercut recovery under state workers’ compensation laws.

McCarran-Ferguson also cements “states rights” thinking about workers compensation. Such thinking precludes the possibility of federal intervention for the benefit of employees that helped workers in the 1970s and 1980s. Originalist thinking and the Lochner era thinking behind McCarran Ferguson by plaintiff’s attorneys also prevents thinking how to make much needed reforms to our social insurance system in general.

Arguments against COVID safety standards in meatpacking sound same in court and in the Unicameral

Posted on May 10, 2021 by Jon Rehm

Nebraska legislators narrowly advanced legislation, that if enacted, would mandate basic COVID-19 safety measures at meatpacking plants.

State Senator Tony Vargas of Omaha introduced the bill to protect meatpacking workers. According to Vargas, 7382 meatpacking workers contracted COVID-19, 256 were hospitalized and 23 died due to the COVID-19 pandemic.

I support this legislation. Early on in the pandemic, I wrote about why I thought workers’ compensation laws weren’t suited to help workers effected by the pandemic. The bill includes requirements about reporting COVID-19 exposure which would aide in prosecuting workers’ compensation cases related to COVID-19.

But, the bill does not include a presumption of workers compensation coverage for COVID-19 exposure. One would think that relatively mild legislation would face little opposition. But that assumption would be wrong.

Somewhat unsurprisingly the arguments used by opponents of COVID-19 safety measure opponents mirrored arguments made by packinghouses in COVID-related litigation. Some legislators argued that the state should not regulate workplace safety in meatpacking houses because that was the job of the federal government. In short, the state was pre-empted from regulating safety conditions in meatpacking plants.

Tyson Foods made similar arguments about federal preemption in their defense to an Iowa state law case involving a lawsuit against Tyson for having their managers make bets on COVID-19 death tolls in an Iowa plant.

I think the preemption argument is specious because states clearly have the right under the 10^th Amendment to make laws about health and safety. That’s the constitutional basis for workers’ compensation laws.

On the flip side, the basis for the federal government to regulate meatpacking stems from the interstate commerce clause. Meatpacking is one of many businesses in Nebraska engaged in interstate commerce. Under the theory advanced by opponents of safeguards for meatpacking workers, the state wouldn’t have the right to regulate those industries either.

Federal and state laws conflict all the time in matters of workplace safety and the effects of workplace injury. Meatpacking plants in Nebraska are largely operated by large multi-national firms with armies of lawyers who comply with all sorts of rules and regulations in different states and countries.

In my view, the packing plants exploited a gap in workers compensation laws to largely avoid paying COVID-19 benefits under workers’ compensation. The standards proposed by Senator Vargas are reasonable, constitutional and should have passed with little debate last year when they were originally proposed.

Tyson Foods seeks friendlier Federal venue for COVID betting case

Posted on April 26, 2021 by Jon Rehm

Tyson Foods is seeking to move the lawsuits from state to federal court of the surviving family members of Tyson employees who died of COVID-19 who sued the company over managers betting on COVID-19 deaths at totals of the company’s Waterloo, Iowa plant.

So why does it matter whether the case is tried in state or federal court? Part of the reason is the composition of the jury pool.

Jury pools in packing house towns

I had a jury trial scheduled the third week of April in Dawson County, Nebraska. The largest private employer in that county is Tyson Fresh Meats in Lexington, Nebraska. In the 27-person jury pool, I had four current employees of Tyson. There were likely other who had worked at Tyson or had friends or family who worked at Tyson.

But in a federal court jury pool in Nebraska, there are likely to be fewer jurors who work in meatpacking or know someone who works in meatpacking. Similar dynamics would likely be in play in Iowa which is demographically similar to Nebraska.

Why it’s harder for Tyson to remove the COVID-19 lawsuit to federal court than typical in this case.

Oftentimes cases against large employers are removed to federal court under so-called diversity jurisdiction because the employee and employer are citizens of different states.

However, the Iowa workers compensation act authorizes a tort claim against co-workers for work injuries due to gross negligence. The plaintiffs in the COVID-19 betting pool case are bringing this case under Iowa’s gross negligence law. Since the cause of action arises under Iowa’s workers’ compensation law, it can’t be removed into federal court.

But Tyson isn’t arguing that for removal from state to federal court on diversity jurisdiction. Tyson is arguing for removal based on acting under a federal order during the height of the COVID-19 pandemic.

The Defense Production Act and pre-emption

In April 2020, then President Trump signed an executive order immunizing meatpackers for civil liability for COVID during the pandemic under the Defense Production Act. I wrote a post about the dubious constitutionality of that order last year.

19 State Attorney Generals from predominately Democratic-controlled states filed a brief in the 8^th Circuit Court of Appeals arguing against removal. The brief gave a detailed explanation of why the Defense Production Act shouldn’t apply and also shot down other pre-emption arguments raised by Tyson.

Importantly, the brief for the Democratic AGs re-enforced the importance of state law in enforcing workplace safety laws. It will be interesting to see how the 8^th Circuit Court of Appeals rules as it could reveal their thinking about whether federal courts are willing to apply federal law in traditional areas of state jurisdiction like workers’ compensation.

Supreme Court holds state laws against drug price hosing not preempted by ERISA

Posted on January 18, 2021 by Jon Rehm

The Supreme Court ruled 8-0 that state laws regulating pharmacy benefit managers (PBMs) were not pre-empted by the federal Employee Retirement Income Security Act (ERISA). The substantive outcome and the reasoning on preemption could impact workers compensation issues like opioid prescription abuse and air ambulance charges.

Opioid use

Many states have introduced drug formularies or lists of approved drugs to limit opioid use and abuse in workers’ compensation claims. Drug formularies are run by pharmacy benefit mangers or PBMs which make their money negotiating discounts between drug companies and drug dispensaries. Critics of PBMs argue that their business encourages higher drug prices so they can make more money on the supposed discount.

One Ohio workers’ compensation official stated that a PBM was “hosing” the state of Ohio with high costs in their drug formulary. The new Supreme Court decision could encourage states to adopt formularies in workers’ compensation without having to worry about unfair drug prices.

I emailed fellow workers compensation Jon blogger, Jon Gelman, that I was semi-pleasantly surprised about the decision on PBMs. My feeling that the federal rock of preemption will usually crush the state scissor of state workers’ compensation laws is a common feeling in the plaintiff’s bar. But Justice Sotomayor’s no-nonsense opinion in the Rutledge case, indicated that the supposedly broad pre-emptive effect of ERISA isn’t as broad as commonly believed.

Air ambulance charges

The Rutledge decision gives me some hope about another conflict between federal law and state workers’ compensation law – air ambulance billing. The issue with air ambulance billing poses the federal governments right to regulate air travel charges through the Airline Deregulation Act (ADA) against the right of a state to regulate insurance charges. The issue is important because of the high cost of air ambulances.

Federal and state courts have almost uniformly held that the federal law on air travel preempts state law on what air ambulance providers can charge. But the Supreme Court has used the preemption language in ERISA as a model for interpreting airline deregulation law.

The Supreme Court may soon take up the issue of whether state regulation of air ambulance charges is preempted by federal law. The air ambulance industry has filed an appeal with the Supreme Court asking to overturn a Texas state supreme court decision that held that state laws regulating air ambulance charges was not preempted by federal law. Since there is now a conflict between jurisdictions involving a large state like Texas, the Supreme Court may take up the issue.

One interesting fact about Texas workers’ compensation law is that they do not fee schedule air ambulance charges. The Texas Supreme Court used that fact to distinguish their decision from other decisions involving state laws that were preempted because of a fee schedule. Personally, I think if Texas won in the Supreme Court because of the fee schedule issue, that would be a hollow victory. I believe the use of fee schedules benefits workers because it keeps disputes between payors and medical providers out of court.

Mc Carran-Ferguson

Workers’ compensation laws are commonly regarded as insurance laws, so there is a strong argument that they should not be preempted under the McCarran- Ferguson Act. That law holds that insurance regulation is a state concern. McCarran-Ferguson is often referred to as “reverse preemption” law . A concurring opinion in the Texas Supreme Court air ambulance discussed McCarran-Ferguson in depth. However, the dissenting opinion in the case held that workers’ compensation was not a law regarding insurance but a law that regulates the relationship between the employee and employer. If the Supreme Court takes up the Texas appeal, it may answer the question of whether workers’ compensation is a law about insurance or the workplace relations? In doing so, it may jolt some long-held assumptions about workers’ compensation.

Unless you have Marine One, Air Ambulances are a pricey proposition

Posted on October 5, 2020 by Jon Rehm

Last Friday President Trump travelled to Walter Reed Hospital in the Presidential helicopter, Marine One, to seek treatment for COVID-19. The President has use of a helicopter, most of us don’t. Sometimes air ambulances are necessary, particularly in remote rural areas, to transport individuals with severe injuries or illnesses.

But if you read this blog, you know that air ambulance bills are often incredibly expensive — and even worse not covered by insurance.

So why are air ambulance charges often not covered by insurance?

Preemption: Federal rock breaks state scissors

Air ambulances are regulated by the Federal Aviation Administration. The authority for this regulation is the so-called interstate commerce clause. Insurance, whether health insurance or workers compensation, is governed by state law because Congress ruled that insurance regulation is the purview of state law. Workers’ compensation laws are state laws that are constitutionally valid due to a state’s general police powers under the 10^th Amendment.

So when accident victims try to pay for an air ambulance charge with health insurance or through workers’ compensation insurance, air ambulance providers argue they aren’t bound by state laws regulating insurance since they are regulated by the federal government.

This argument is called preemption. Preemption means that if state and federal laws conflict on a subject that federal law governs. In other words, the federal rock crushes the state scissors. A majority of courts side with the air ambulance companies in holding that federal law regulating air ambulances pre-empts states from using their laws on insurance to regulate air ambulance charges.

In practical terms, injury cases involving air ambulances are more difficult to resolve. Fortunately, air ambulances aren’t covered by Nebraska’s lien statute which gives doctors and other providers a right to recover unpaid bills out of a personal injury settlement. This can give attorneys some leverage over these providers

What would the Founding Fathers think about air ambulances?

Before he went to the hospital, the President nominated 7th Circuit Court of Appeals Judge Amy Coney Barrett to replace Ruth Bader Ginsburg on the Supreme Court. Barrett’s views on abortion and other hot button social issues have drawn attention. But the bulk of cases decided by federal courts tend to be esoteric and obscure issues like air ambulance charges that stem from tensions within the United States Constitution.

I don’t know if Barrett has ruled on an air ambulance case. Barrett is known as an “originalist” or someone who looks at the intentions of the Founding Fathers in interpreting the Constitution.

But in my mind air ambulance cases are one example of the limits of the originalist approach. Passenger air travel post-dates the Constitution by about 130 years. What would the Founding Fathers know about air ambulances? Anyone who brings an originalist approach to deciding an issue like air ambulance charges is just dressing up their policy preferences in late 18th century garb.

Immunity by executive order probably isn’t constitutional, but beware of federal immunity for COVID-19 in workers’ compensation

Posted on May 4, 2020 by Jon Rehm

The Supreme Court held that Harry Truman overstepped his authority under the Defense Production Act in *Youngstown Sheet and Tube*

Last week, President Donald Trump signed an executive order shielding meatpacking firms like Tyson from legal liability over COVID-19. Trump’s order was based on the Defense Production Act (DPA).

Seeing the forest from the trees

From a legal perspective, the order is unenforceable. But getting bogged down in the legal weeds misses an important point about the order. The President of the United States has stated that packinghouses are immune from liability under the law for COVID-19 exposure. Regardless of the legal technicalities, that statement will likely discourage workers from filing workers’ compensation claims against meatpackers. I also fear managers of those plants will use the order as an excuse to shift the cost of COVID-19 exposures onto enhanced unemployment or short-term disability policies if workers file those claims.

Executive orders and Youngstown Sheet and Tube

Federal courts have held that the Defense Production Act does not immunize corporations from tort claims. Furthermore, in order to invoke the Defense Production Act, it would appear a company needs to be performing an actual government contract. The DPA fails to shield companies that are just producing their product for the private market.

But even if the DPA applies to meatpackers during the COVID-19 pandemic, the President has limited powers under the DPA. In 1952, President Harry Truman tried to use the DPA to force steel production during the Korean War. In Youngstown Sheet and Tube v. Sawyer, the Supreme Court held that since Congress had not specifically authorized such an order that Truman’s order was unconstitutional. Cheap meat during a pandemic is hardly the national security crisis that a shortage of steel during a major war.

Legally, this executive order immunizing packinghouses from COVID-19 claims should be filed in a recycling can. But corporate America is already planning to immunize itself from litigation from COVID-19 in a way that could be enforceable. I also believe these efforts will be aimed at workers’ compensation.

Federal legislation and COVID-19 immunity

The legal problems with Trump’s order on immunizing meatpacking plants under the DPA is the lack of Congressional authority. However, the Senate is proposing legislation that would prevent consumers and employees from suing corporations for exposure to COVID-19

Opponents of this legislation, point out, like I have earlier, that suits against businesses for COVID-19 are hard to prove. Opponents of the legislation also argue like I have earlier, that workers’ compensation already limits the liability of corporations for COVID-19 exposure from their employees.

My guess is that many readers of this blog possess some expertise in the workers’ compensation and workplace law general. I can imagine those readers saying something a long the lines of “Even if McConnell’s federal tort reform plan gets past Nancy Pelosi, there is no way it would apply to workers’ compensation. Workers’ compensation is a state issue.”

I believe this argument amounts to wishful thinking.

The 10^th Amendment and workers’ compensation

Most workers compensation lawyers would argue that that two propositions would prevent Congress from giving federal immunity to employers under state workers’ compensation laws for COVID-19 exposure. One, workers’ compensation laws are enacted under 10^th Amendment police powers. Workers’ compensation is also a law regulating insurance. State law generally governs insurance under the McCarran-Ferguson Act.

But federal and state courts have questioned the applicability of state workers’ compensation laws in regulating air ambulance charges. In technical legal jargon, state workers’ compensation laws have been mostly preempted by federal law on air ambulance charges because regulation of air ambulances is a matter of federal law. I believe the air ambulance charge cases could persuade courts that federal immunity for COVID-19 litigation would apply to workers’ compensation cases.

The 10^th Amendment and state quarantine orders

The 10^th Amendment is also the constitutional authority state governors and local officials rely upon for stay at home orders. President Trump has attacked some Governors for invoking that authority to impose quarantine or shelter in place order.

But more importantly, Attorney General William Barr has stated the Department of Justice will question state laws related to COVID-19 that unduly inhibit national commerce. Barr seems to be reviving the concept of the “dormant commerce clause”. Federal courts used the dormant commerce clause to overturn state laws regulating the workplace in the Lochner era.

I believe corporate America and their political allies will use federal legislation to undercut state workers’ compensation laws. Advocates fro injured workers should stay vigilant during this crisis.

Air ambulance charges continue to vex

Posted on October 17, 2019 by Jon Rehm

Concerns about air ambulance charges have migrated from the tiny niche of workers’ compensation blogs to national publications such as the Los Angeles Times.

Media outlets featured coverage of families were stuck with hefty medical bills when health insurance failed to come anywhere near paying the cost of air ambulance charges leaving consumers with charges approaching $50,000.

Air ambulances are exploiting a loophole in insurance regulation. Insurance, including health insurance and workers’ compensation, is regulated by states. But air ambulances are regulated by the Federal Aviation Administration. Air ambulance companies have been mostly successful in persuading courts that since they are regulated by the federal government, state insurance laws should be pre-empted and not applicable to them when it comes to their charges.

Many of the challenges to applicability to state laws in air ambulance charges have come from workers’ compensation cases. Workers compensation laws are state laws because the federal government had very limited power to regulate the workplace when workers’ compensation laws were enacted early last century.

Back in January I wrote about a new federal regulation that might allow some regulation of air ambulance charges. I still believe that the fact there is now some regulatory guidance on air ambulance charges may strengthen the case on preemption. The best fix to air ambulance charges may be federal legislation.

Nebraska recently enacted legislation that allows injured workers to delay the collection of unpaid medical bills that are part of a workers’ compensation case. I would imagine air ambulance companies will attempt to use preemption arguments to blunt the effects of that law in workers’ compensation cases.

Air ambulance charges are a subject of high interest to lawyers in Nebraska and other rural states. Injury victims in rural areas often require air transportation for emergency medical conditions. Air ambulance charges are often complicate the resolution of workers’ compensation and personal injury cases

Federal preemption of air ambulance charges adds other insults to injury to rural residents and rural states. Air ambulance providers base their preemption arguments on the same law that deregulated commercial air travel. Airline deregulation greatly reduced commercial air travel in rural areas to the detriment of economic development and quality of life. So the same law that largely took away commercial air service from rural areas serves to soak rural residents who suffer serious injuries and illnesses.

If nothing else maybe air ambulance carriers should be subsidized through the Essential Air Service program so that their services are not unduly expensive to rural residents.

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Tag Archives: preemption

U.S. v. Washington: A rock, paper, scissors theory of federal preemption of workers’ comp. laws?

Is it better that SCOTUS punted on air ambulance cases

Arguments against COVID safety standards in meatpacking sound same in court and in the Unicameral

Tyson Foods seeks friendlier Federal venue for COVID betting case

Supreme Court holds state laws against drug price hosing not preempted by ERISA

Unless you have Marine One, Air Ambulances are a pricey proposition

Immunity by executive order probably isn’t constitutional, but beware of federal immunity for COVID-19 in workers’ compensation

Seeing the forest from the trees

Executive orders and Youngstown Sheet and Tube

Federal legislation and COVID-19 immunity

The 10^th Amendment and workers’ compensation

The 10^th Amendment and state quarantine orders

Air ambulance charges continue to vex

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Seeing the forest from the trees

Executive orders and Youngstown Sheet and Tube

Federal legislation and COVID-19 immunity

The 10th Amendment and workers’ compensation

The 10th Amendment and state quarantine orders

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The 10^th Amendment and workers’ compensation

The 10^th Amendment and state quarantine orders