Sedgwick Claims Management Services v. Norwood

Employee’s injuries sustained while taking a document to the post office for Employer do not fall under the exception to worker’s compensation compensability for recreational or social activities “primarily for the worker’s personal pleasure.”

Employer appealed an award of worker’s compensation to Employee for injuries sustained while running an errand for Employer. Employer mentioned that an envelope had to go to the post office, and Employee offered to walk to the post office and drop it off; Employer assented, knowing that Employee enjoyed taking walks. When leaving the bank on the way back to work, Employee was injured by a car. Applying Roberts, the Worker’s Compensation Board held that Employee’s actions do not fall under the exemption for recreational or social activities because the Employer benefited from the Employee’s actions, and there was not sufficient proof that the reason that Employee took the envelope to the post office was principally for her own personal pleasure in walking. The Court held that the Worker’s Compensation Board properly concluded that the exclusion did not apply. Affirmed.