Pennsylvania Appellate Court Holds Employee Injured While Running in Employer’s Parking Lot Not Entitled to Benefits
Recently, the Pennsylvania Commonwealth Court addressed whether an employee had suffered an injury in the course and scope of employment, under the state Workers’ Compensation Act. Pennsylvania law requires that for a workplace injury to be compensable, the injury or accident must occur in the course and scope of employment. At issue in the present case was whether the injury was related to the employment, since the employee fell in his employer’s parking lot.
James Shaw testified that while working at the warehouse of Quality Bicycle Products, he received a telephone call indicating that his daughter was missing from school. He informed his manager he had to leave work due to a family emergency. While hurrying to his vehicle, about 10-12 feet away in the parking lot of the warehouse, he felt his knee pop and suffered excruciating pain. He fell to the ground and was taken to the hospital. Days later, he underwent knee surgery.
Mr. Shaw testified that the parking lot is where all the workers at Quality Bicycle Products park and that there had not been an abnormality in the parking lot that led to his fall.
The Workers’ Compensation Judge found that Mr. Shaw’s testimony was credible and persuasive and concluded he was on his employer’s property, in the course and scope of his employment, when he was injured. The judge granted his petition, and Quality Bicycle Products appealed to the Workers’ Compensation Appeals Board. They affirmed the granting of his claim petition, and Quality Bicycle Products appealed.
Quality Bicycle Products argued that Mr. Shaw had not been furthering the interest of Quality Bicycle Products’ business when he was injured, and there was no evidence the injury was caused by a condition on their premises, or by the operation of their business.
The appellate court stated a workers’ compensation claimant must prove all of the elements of a claim to support their award. Their injury must arise in the course and scope of employment and be related to the employment. While an injury suffered going to or coming from work is not considered to have occurred in the course and scope of employment, if that injury is on the employer’s premises at a reasonable time before or after work, the claimant may be entitled to benefits.
If an employee is not furthering the business of his employer, he must show that the injury occurred on the employer’s premises, his presence was required by his employment, and the injury was caused by a condition on the premises. Quality Bicycle Products argued that Mr. Shaw met the first two prongs but did not show that a condition on the premises led to his injuries. In fact, his running caused his injury. Mr. Shaw contended that he need only show the business played a small role in the chain of causation.
The appellate court stated that the parking lot did not contribute to or cause Mr. Shaw’s injury. Mr. Shaw himself admitted there was not a condition on the lot that caused his injury. He therefore failed to prove a connection between his injury and the condition of Quality Bicycle Products’ premises.
The appellate court concluded that the WCJ erred in holding that Mr. Shaw met his burden of proving his injury was caused by the condition of the property or Quality Bicycle Products’ operation of their business on the premises. The lower court’s judgment was reversed.
The workers’ compensation attorneys at Needle Law help individuals in Pennsylvania seek benefits for their work-related injuries. If you were injured in the course and scope of your employment, contact our office today at 570-344-1266 for a no-cost consultation.