20 N.Y.2d 881 (1967)
An employee’s injury does not arise out of and in the course of employment when it occurs after the work-related function has concluded and the employee engages in substantial, purely personal activity that materially increases the risk of injury.
Summary
This case concerns a claim for workmen’s compensation benefits following an employee’s death in a car accident after attending a dinner with fellow employees. The Court of Appeals affirmed the award of benefits, holding that the employee’s attendance at the dinner was within the scope of employment. The dissent argued that the employee’s extended stay at a tavern after the dinner, until 4:00 AM, constituted a deviation from employment, making the subsequent accident a result of personal activity, not arising out of employment. The majority’s brief per curiam opinion references prior rulings without detailing its reasoning.
Facts
The employee, Mansfield, attended a dinner with fellow employees. After the dinner, Mansfield remained at a tavern until approximately 4:00 AM. Subsequently, Mansfield was involved in a fatal car accident.
Procedural History
The Workmen’s Compensation Board awarded benefits to Mansfield’s estate. The Appellate Division affirmed. This appeal followed to the New York Court of Appeals.
Issue(s)
Whether the employee’s fatal car accident arose out of and in the course of his employment, considering his attendance at a company dinner followed by several hours at a tavern.
Holding
Yes, because the Court of Appeals, in a brief per curiam opinion, affirmed the lower court’s decision, citing prior cases where attendance at a company-related event was deemed within the scope of employment.
Court’s Reasoning
The majority affirmed the lower court’s decision with a brief citation to prior cases, including Matter of Graves v. Tide Water Oil Sales Co. and Matter of Lowery v. Riss & Co. These cases generally suggest that injuries sustained while attending employer-sponsored or work-related social events can be compensable under workmen’s compensation laws.
The dissenting judge, Van Voorhis, argued that even if attending the dinner was initially within the scope of employment, Mansfield’s actions after the dinner constituted a significant deviation. The dissent emphasized the lengthy period between the dinner’s conclusion (11:00 PM) and the accident (4:00 AM), arguing that Mansfield’s personal activity during those hours materially increased the risk and severed the connection to his employment. As the dissent stated, “This personal activity on his part materially added to the risk and, in my judgment, constituted a deviation from the course of his employment if his attendance at the dinner could be regarded as having been work connected in the beginning.”
The brevity of the majority opinion makes it difficult to fully discern their reasoning beyond reliance on precedent. The dissent highlights a critical point: the temporal and causal connection between the employment and the injury. The long intervening period of purely personal activity was, in the dissenter’s view, enough to break that connection.