(Credit: Daniel/Adobe Stock) Under the extended premises doctrine, an employee may suffer a compensable injury even though the accident was on property not owned by the employer because the property was “in such proximity and relation to the space leased by the employer as to be in practical effect the employer’s premises.” (Credit: Daniel/Adobe Stock)

The Virginia Court of Appeals has held that the extended premises doctrine expanded United Continental Holdings’ premises beyond its physical terminal, after an employee injured herself near the terminal entrance.

Affirming the Virginia Workers’ Compensation Commission’s judgment awarding a United Airlines customer service representative’s compensable injury, the court concluded defendant Milly Sullivan fell and injured herself on United’s premises, as the incident occurred in sufficient proximity to the terminal.

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