Lack of significant relationship to Connecticut foils claim

A worker must show a significant relationship between Connecticut and either the employment contract or the employment relationship.

Case name: Baron v. Genlyte Thomas Group, LLC, et al., No. AC 32636 (Conn. App. Ct. 01/03/12).

Ruling: The Connecticut Appellate Court held that it did not have jurisdiction over a salesman's claim for benefits.

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What it means: Connecticut holds jurisdiction over a workers' compensation claim if it was the place of the injury, the place of the employment contract, or the place of the employment. A worker must show a significant relationship between Connecticut and either the employment contract or the employment relationship.

Summary: An outside salesman for a manufacturer of lighting fixtures lived in Connecticut. He entered into an employment contract in New Jersey, where the manufacturer's headquarters were located. He also attended sales meetings three times per month in New Jersey. The salesman's territory consisted of three New York counties, and he had one client in New Jersey. The salesman sustained injuries in a car accident in New York while he was driving to a sales meeting in New Jersey. He died five months later, and his estate sought benefits. The Connecticut Appellate Court held that it did not hold jurisdiction over the claim because Connecticut had only a "peripheral relationship" to the employment.

The court concluded that the estate did not show a significant relationship between Connecticut and the employment relationship. The estate claimed that the salesman had a home office. The court explained that even if he often worked in his home office, he did not have a "desk job." The court said that the decision of a traveling salesman to perform certain aspects of his job at home for convenience was insufficient to establish a significant relationship between Connecticut and his employment.

The estate also claimed that the salesman sometimes worked in Connecticut when a New York customer purchased lighting for a Connecticut store. The court pointed out that the salesman was discouraged from pursuing clients in Connecticut because it was a coworker's territory. Occasional and infrequent business in Connecticut did not establish a significant relationship. The court noted that the manufacturer was not aware that the salesman assisted customers in Connecticut.

Read more at the WorkersComp Forum homepage.

February 13, 2012

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