Matter of Ford v. Unity House, 84 N.Y.2d 857 (1994)
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An assault on an employee by a coworker is compensable under workers’ compensation if it arises out of and in the course of employment, and a statutory presumption exists that an assault during employment arises out of employment unless substantial evidence shows purely personal animosity.
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Summary
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This case addresses whether an employee’s death, resulting from an assault by a coworker, is compensable under workers’ compensation. The Court of Appeals affirmed the Appellate Division’s order, holding that the death was compensable because the assault was rooted in events connected to the workplace. Even though the death occurred in a stairwell outside the employer’s premises, the initial encounter and the commute to the office supported the finding that the assault arose in the course of employment. The court also relied on the statutory presumption that an assault during employment arises out of the employment itself, absent substantial evidence of purely personal motivation.
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Facts
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The decedent was assaulted and killed by a coworker. The initial encounter between the two occurred in the lobby of the building where the employer’s offices were located as the decedent arrived for work. The two then rode the elevator together towards the employer’s 17th-floor offices. The actual assault and death occurred in an 18th-floor stairwell, not technically part of the employer’s premises. Evidence suggested a possible dispute over a loan between the coworkers, a practice condoned by the employer. The coworkers had no social ties outside of work.
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Procedural History
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The Workers’ Compensation Board initially determined that the death was compensable. The Appellate Division affirmed this decision. The case then went to the Court of Appeals.
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Issue(s)
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Whether the decedent’s injuries and subsequent death are compensable under workers’ compensation as arising out of and in the course of his employment, considering the assault occurred outside the employer’s immediate premises but was initiated within the building and involved a coworker.
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Holding
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Yes, because the assault was