If an employee is killed in a crash on their way to an employer-sponsored class, is their spouse entitled to benefits through workers’ compensation? Yes, if the employer derives a special benefit from the employee’s activities.
In Lewis v. LexaMar Corp., the Michigan Supreme Court reversed a Dec. 17, 2020, appeals court decision that denied benefits to the widow of a worker who was killed on his way to a community college to take a class paid for by his employer.
Agreed to attend class only if employer paid for it
Buddy Lewis, Sr. worked at LexaMar Corporation in Boyne City, Michigan, and was a student at Kirtland Community College in the Magnatronics program, according to law firm Foster Swift Collins & Smith. He was enrolled in the program at the encouragement of his employer’s human resources director. Further, he only agreed to attend the class after the company said it would pay all of his tuition.
LexaMar didn’t require Lewis to sign a reimbursement agreement or commit to continue working for the company as a condition of his enrollment in the class.
Lewis was killed on his way to the college class after working his night shift job.
The state’s workers’ compensation magistrate and the Michigan Compensation Appellate Commission awarded benefits to Lewis’ widow, but the Michigan Court of Appeals reversed the decision, finding Lewis wasn’t in the course of employment when the accident occurred.
Exception to ‘going or coming’ rule
On April 1, 2022, the state’s Supreme Court reversed the appeals court decision, finding LexaMar derived a special benefit from using Lewis as a test case to decide whether to send other employees to the college for vocational training or bring instructors to the company for classes.
This special benefit meant Lewis’ incident was an exception to the “going or coming” rule that prevents employers from being held liable for employee injuries that occur going to, or coming from, the workplace.