The Supreme Court of Georgia has ruled in favor of a State Farm employee who was injured when she slipped and fell on a wet floor in the break room in the middle of the day while getting ready to eat her lunch was injured during the course of employment, because it logically follows that her injury was causally connected to the conditions under which she worked, and therefore, her injury arose from her employment. The case is Frett v. State Farm Emple. Workers' Comp., 2020 Ga. LEXIS 458.
According to the undisputed case facts, on the day of the incident, State Farm employee Rochelle Frett logged out of the phone system for her scheduled, unpaid forty-five-minute lunch break and went to the breakroom to microwave her food. While exiting the breakroom to enjoy her lunch outside the building, she slipped on some water on the floor and fell.
Frett was initially awarded workers' compensation benefits by an administrative law judge. On appeal, the State Board of Workers' Compensation on appeal denied her claim for workers' compensation and a superior court later upheld the decision. The Court of Appeals affirmed the decision holding that Frett suffered no injury compensable under the Act because Frett sustained her injury during a scheduled break so the injury did not arise out of her employment.
The Supreme Court of Georgia reversed, finding that Frett sustained the injury in the course of her employment and that it "is undisputed that she was injured on the premises of her employer, in the middle of her workday, while preparing to eat lunch." The court also stated that the activity of eating lunch was reasonably necessary to sustain her comfort at work, so it was incidental to her employment and not beyond the scope of compensability under the Workers Compensation Act.
Editors Note: An accident that occurs in the course and scope of employment should be covered under the workers' compensation system. An accident that happens during an unpaid lunch away from work premises usually isn't in the course and scope of employment, so they are usually not covered. In this case, the court found that coverage applied because the employee was still on work premises, and eating lunch was reasonably necessary to perform the employee's work at the company comfortably, so it was incidental to her employment.