An employee went to the company vending machine to get a snack. She slipped, fell and fractured her pelvis. She applied for workers’ comp which her employer denied. How did a court rule?
Joyce Wood worked as a part-time receptionist for the Centers for Youth & Families (CFYF) in Arkansas. On Jan. 14, 2014, when there was a lull in activity at the front desk, Wood walked to the vending machine. On her way there, she slipped on water in the hallway and fell, fracturing her pelvis.
When she applied for workers’ comp, her employer denied her claim. She took her case to the Arkansas Workers’ Compensation Commission where an administrative law judge (ALJ) heard her appeal.
Wood said that on a typical day, after going to the vending machine, she would immediately return to her desk where she could eat her snack and perform her job duties.
Finding Wood to be “an extremely credible witness,” the ALJ found her injury compensable. On appeal, the Commission upheld the ALJ’s rule.
CFYF took its case to a state appeals court.
Did she leave her job duties?
The appeals court said the test in these cases is whether the employee was carrying out the employer’s purpose or advancing the employer’s interest, directly or indirectly.
CFYF pointed to another case to make its argument. In that case a truck driver, who was responsible for his vehicle and its contents at all times, left his truck at the loading dock to use the restroom. After using the restroom, the driver went into a break room to get a snack from a vending machine. While in the break room, the driver slipped, fell and injured his shoulder.
The Arkansas Court of Appeals decided the driver was doing the exact opposite of what was required of him by failing to stay with his truck and that he wasn’t in a position to perform his job duties.
But the appeals court said Wood’s case was different. Wood was permitted to leave her work station for various reasons, including getting a snack from the vending machine, as long as the telephone wasn’t ringing and guests weren’t in the reception area.
The court said the Commission could reasonably conclude that Wood’s brief trip away from her desk to get a snack didn’t detract from her job duties, which benefited her employer, directly or indirectly.
For that reason, the appeals court upheld the Commission’s ruling that Wood should receive workers’ comp benefits for her broken pelvis due to the fall.
What do you think about the court’s decision? Let us know in the comments.
(Centers for Youth & Families v. Joyce A. Wood, Arkansas Court of Appeals, No. CV-15-36, 6/17/15)