Matter of Koerner v. Prestige Point, Inc., 22 N.Y.2d 540 (1968)
An injury sustained by a traveling employee is not compensable under workers’ compensation if the injury is solely attributable to the employee’s personal act and not to any environmental factor related to the employment.
Summary
Koerner, a traveling salesman, sought worker’s compensation benefits for a back injury sustained while he was on a business trip. The injury occurred in his motel room when he lost his balance while putting on his trousers. The Workmen’s Compensation Board awarded benefits, but the Court of Appeals reversed, holding that the injury was not work-connected because it was solely the result of the claimant’s personal act and not linked to any environmental factor arising from his employment. The court distinguished cases involving household employees and those where the work environment contributed to the injury.
Facts
The claimant, a traveling salesman, was on a business trip in Chicago and was scheduled to travel to Duluth, Minnesota. While dressing in his motel room at 8:30 a.m., he was rushing to get ready and begin driving. He lost his balance and fell while putting on his trousers, resulting in back injuries.
Procedural History
The Workmen’s Compensation Board awarded compensation to the claimant. The Appellate Division affirmed the Board’s decision, finding that the injury was work-connected as a question of fact. The employer appealed to the New York Court of Appeals.
Issue(s)
Whether a traveling employee’s injury, sustained while performing a personal act (dressing) in a motel room during a business trip, is compensable under workers’ compensation when the injury is not attributable to any environmental factor related to the employment.
Holding
No, because the injury was solely attributable to the claimant’s personal act of losing balance while dressing and was not caused by any environmental factor associated with his employment.
Court’s Reasoning
The Court of Appeals distinguished this case from prior cases where injuries to traveling employees were deemed compensable because those cases involved an environmental factor related to the employment (e.g., slipping in a bathtub, insect bites in a particular region, or unique risks associated with living at the place of employment). The court emphasized that “for compensation purposes an injury suffered by an employee while out of town on the business of his employer may be ‘work connected’ even where the employee at the time of the accident was not actively engaged in the duties of his employment.” However, the court drew a line, stating, “Where an accident is attributable solely to the personal acts of the claimant, and cannot be attributed in any way to the environment into which the employee has been brought by his employment…such injury or death ought to be held noncompensable.” The court noted that the accident could have occurred anywhere, and the motel room itself did not contribute to the injury. The court also declined to extend the special exception afforded to household employees (where virtually any injury is compensable) to other classes of employees. The court distinguished cases like Matter of Miller v. Bartlett Tree Expert Co., 3 Y 2d 654 (employee slipped in a bathtub) arguing in those cases, the injury was due at least in part, to an environmental factor. In Koerner, the sole cause was the claimant’s loss of balance.