Comp covers director's injuries while driving from work to store
Goss v. North Shore Trust & Savings, 20 ILWCLB 189 (Ill. W.C. Comm. 2012).
Ruling: The Illinois Workers' Compensation Commission held that a director's injuries sustained in a vehicular accident while driving from work to a retail store at the end of her workday were compensable.
What it means: In Illinois, a worker can be entitled to workers' compensation for injuries sustained in a car accident if she was on a work-related trip to a store.
A director of investments' job responsibilities included marketing and promoting the employer's business within the local community. She participated in an annual business exposition. In preparation for the event, she decided to purchase a rug for the employer's booth. At the close of the employer's business hours, the director left the office and headed to a retail store to purchase the rug. While on the way to the store, she was involved in a collision with another motor vehicle. The commission affirmed the arbitrator's finding that she was entitled to benefits.
The arbitrator noted that the director's job duties routinely required her to travel away from the employer's offices at times outside of the regular business hours to participate in organizations and events on behalf of the employer. The employer provided her with the discretion to purchase items for the benefit of or in furtherance of its business. There was no evidence that her trip to the retail store was for any purpose other than attempting to purchase the rug. Also, because the retail store was not located along the director's normal route home from work, she was not merely on her way home from work when the accident occurred.
The arbitrator determined that the director's injuries occurred while she was acting for the benefit of the employer. In addition, her trip to the retail store was reasonable and foreseeable and within the scope of her job duties.
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April 1, 2013
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