Legacy Health Systems v. Noble

An injury arises out of employment when the risk is connected with the nature of the work or the work environment.

Noble is an employee of Legacy Good Samaritan Medical Center (Legacy). During a paid 15 minute break, Noble walked across the street on a personal errand and through a separate parking lot that was owned by Legacy, where she slipped and broke her ankle. Legacy challenged the Workers’ Compensation Board's award of compensation because the accident resulted from a personal errand and not from an employment risk. The Court of Appeals applied the unitary work-connection test and agreed with Legacy that the circumstances of the injury do not fit the purpose of the workers’ compensation laws. A person can recover workers’ compensation for an accidental injury “arising out of and in the course of employment.” An injury arises out of employment when the risk is connected with the nature of the work or the work environment. Here, the fact that Legacy owned the parking lot where Noble fell was merely coincidental since there was no causal connection in the nature of the work or the work environment that exposed Noble to the risk of slipping in a parking lot. Reversed.