Past recreational horseback riding reveals personal mission

In Tennessee, evidence showing that a worker was injured while in the course of a personal mission will block benefits for the worker.

Case name: Parish v. Highland Park Baptist Church, et al., No. E2010-01977-WC-R3-WC (Tenn. 10/18/11, unpublished).

Ruling: In an unpublished decision, the Tennessee Supreme Court held that a manager's injuries that occurred when he was thrown from a horse were not compensable.

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What it means: In Tennessee, evidence showing that a worker was injured while in the course of a personal mission will block benefits for the worker.

Summary: A camp run by a church received four horses from a donation. A business manager for the church implied that the intent was for the horses to be ridden by children campers. The camp director decided that it would be necessary to work with the horses before they could be used at the camp. Although the manager did not usually work on Saturdays, he and his wife visited the camp to check the horses. The manager was thrown off a horse he was riding and sustained a broken bone in his knee and a burst fracture of a vertebra. The injury caused him to have permanent limitations. The manager sought benefits. The Tennessee Supreme Court held that the manager was not entitled to compensation.

The manager argued that his horseback riding bore a "rational connection" to his employment. The court disagreed, pointing out that the church had no expectation that the manager would train or evaluate the horses at the camp. The court said the manager was on a personal mission outside the employment relationship.

The court noted that the manager used camp horses for recreation in the past, the pastor said that the horses were not going to be ridden by campers, and the camp director said that the horses were his responsibility. Also, the pastor was surprised that the manager went to the camp and he said that he never intended for the horses to be used for campers.

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November 17, 2011

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