Matter of মৃত্যুর v. Craig Developmental Center, 36 N.Y.2d 681 (1975)
An employee injured while traveling to a required training course may be eligible for worker’s compensation benefits if the travel is considered an integral part of their employment.
Summary
This case concerns an employee of Craig School who was injured in a car accident while commuting to a practical nursing course required by her employer. The Workmen’s Compensation Board awarded her benefits, finding that the injuries arose out of and in the course of her employment. The Court of Appeals affirmed the award, holding that the travel was indeed incidental to employment. The dissent argued that the claimant had effectively changed her employment situs and the risks she incurred during travel were not unique to the demands of her employment. This case highlights the nuances in determining when travel to training is considered part of the employment for worker’s compensation purposes.
Facts
The claimant, a senior attendant at Craig School for the mentally retarded, was granted a one-year educational leave with full pay to attend a practical nursing course at the Rochester School of Practical Nursing. This leave was granted according to the school’s policy. The claimant was injured in an automobile collision while driving from her home in Dansville, New York, to the Monroe Community Hospital, where the practical nursing course was held. The employer did not reimburse her for tuition or travel expenses, and transportation was the claimant’s responsibility.
Procedural History
The Workmen’s Compensation Board granted benefits to the claimant. The Appellate Division affirmed the Board’s decision. The employer and the State Insurance Fund appealed to the New York Court of Appeals.
Issue(s)
Whether an employee injured in a car accident while traveling to a mandatory educational course, funded and required by the employer, is entitled to worker’s compensation benefits for injuries sustained during the commute.
Holding
Yes, because the travel to the training course was incident to the claimant’s employment, as attendance at the course was required and beneficial to the employer.
Court’s Reasoning
The court reasoned that the claimant’s attendance at the practical nursing course was part of her employment, and her injury during travel arose out of and in the course of her employment. The court distinguished this case from the general rule that commuting to and from work is not covered under worker’s compensation. The court emphasized that the employer encouraged the claimant’s attendance, and the training directly benefited the employer. The court determined that the travel was “an incident of the employment”. The dissent argued that the claimant had voluntarily changed her zone of employment to the Monroe Community Hospital, and the risks she incurred during travel were not peculiar to the demands of her employment. Jasen, J. cited *Matter of De Voe v. New York State Rys.*, stating that travel to and from the place of employment is generally not a covered activity. The dissent distinguished *Matter of Bump v. Central School Dist. No. 3, Montrose*, where death benefits were granted because the decedent was traveling between two zones of employment, arguing that in the present case, the claimant had voluntarily changed her job site to the Monroe Community Hospital.