Arizona court tackles injuries stemming from work-related errands

Arizona’s “going and coming” rule precludes workers’ compensation coverage for injuries that occur during commutes.

In 2012, an Arizona auditor left her job at the end of her shift to run a work-related errand before heading home. According to court documents, she had to deliver a manual at a client's office. On her drive home, she got into an accident and sustained injuries. The woman felt she was entitled to workers' compensation, but an appeals court determined otherwise.

This case illustrates the importance of understanding Arizona's workers' compensation laws. Employees should be aware of the incidents that will and will not be covered.

Case details

The woman initially filed a claim with the Industrial Commission of Arizona. An administrative law judge denied the workers' compensation claim under the state's "going and coming" rule. That rule excludes injuries that occur going to or coming from work, but there are exceptions.

The woman appealed the decision, but the Arizona Court of Appeals upheld the judge's decision. The court ruled that she did not suffer the injury during the course of employment, as she had already completed the errand. Further, the court determined that the woman did not fit into any of the rule's exceptions.

Exceptions to the rule

There are several exceptions to the "going and coming" rule, including the following:

  • The employee was performing a special errand for the employer.
  • The errand is integral to the trip and not incidental to it, as outlined in the dual purpose doctrine.
  • The employee is a firefighter or police officer.

The woman in this case invoked the dual purpose doctrine. However, the court found that she did not meet the requirements for the rule because neither she nor any other worker would have had to make the trip to return the manual out of necessity.

Filing a claim in Arizona

As the Industrial Commission of Arizona points out, anyone who suffers an illness or injury due to job-related circumstances will be eligible for workers' compensation. The commission notes that its claims division evaluates more than 30,000 cases every year to determine eligibility for compensation or review related information.

Anyone who suffers an injury must report it to his or her employer within one year of the incident. The employer or the person's physician will then file a report with the ICA, and the company's insurance carrier will be notified.

As the ICA points out, a claim could be denied due to missing the timeframe or filing incomplete paperwork. Also, as the above case illustrates, employees could be denied compensation if the provider asserts the injury does not meet the necessary requirements. The above decision is not yet final and may be taken up to the Supreme Court. These cases are decided based on their individual set of facts, so it is very important to consult with a specialist to determine whether your case falls within an exception.

Anyone with questions about this matter should consult with an attorney.