Mendoza v. Liberty Northwest Insurance Corporation

An employee who is injured while performing a duty of employment, even a duty not required and off-premises, is in the course of employment if it benefits and is permitted by the employer.

Mendoza sought review of the Workers' Compensation Board’s (Board’s) order that her injury was not compensable because it occurred outside of the course of her employment. Mendoza is a team leader who is responsible for receiving and distributing paychecks to members of her team. The paychecks may either be picked up from the employer's office or received by mail. Mendoza was injured while driving to pick up the paychecks. Mendoza’s employer denied her claim because the injury occurred while she was off work and not being paid. An administrative law judge and the Board both upheld the denial of her claim, and Mendoza appealed. The Court of Appeals found that the employer's authorized method of picking up paychecks was an employment duty that benefited the employer, and therefore claimant's injury did occur within the course of employment. That the activity was not required by the employer, and Mendoza’s doing so was motivated by a desire to retrieve her own paycheck did not render the activity unrelated to work. Reversed and remanded.