Case name: Gazette Communications, Inc. v. Powell, No. 0-633/10-0017 (Iowa Ct. App. 10/06/10).
Ruling: The Iowa Court of Appeals held that a worker was not entitled to compensation for an injury that occurred at a work-related bowling event.
What it means: In Iowa, recreational or social activities may be held in the course of employment when the employer benefits from the activities.
Summary: A worker was injured at a bowling event arranged by his employer's employee activity committee. The event was not held on the employer's premises and attendance at the event was not mandatory. A workers' compensation commissioner found that the injury arose out of and in the course and scope of his employment and was compensable. The Iowa Court of Appeals disagreed and held that the worker was not entitled to compensation for the injury.
A social activity arises out of the course of employment if the employer derives substantial direct benefit from the activity "beyond the intangible value of improvement of employee health and morale that is common to all kinds of recreation and social life." Here, the commissioner found the "sole benefit" to the employer was employee morale and camaraderie among the employees. The court stated that the factual finding was binding. The court explained that the commissioner was incorrect in deciding that this sole benefit was sufficient to bring the bowling event into the course of employment. To apply the standard used by the commissioner would result in complete coverage for all of the employer's social and recreational activities.
Read more at the WorkersComp Forum homepage.
December 20, 2010
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