AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

Four oil field workers, including a driller and his crew, were involved in a single-vehicle rollover accident while traveling to a mobile drilling rig for their shift. The driller customarily transported his crew in his personal truck, and on the day of the accident, another crew member drove after the driller felt too tired. The accident occurred when the driver fell asleep, resulting in one fatality and injuries to the others.

Procedural History

• Workers’ Compensation Administration, Helen L. Stirling, Workers’ Compensation Judge: Dismissed the workers’ claims, holding that the accident did not occur within the course of employment and did not meet exceptions to the going and coming rule.

Parties' Submissions

• Appellants (Workers): Argued that the accident fell within the traveling employee exception to the going and coming rule due to the mobile nature of the job site and the driller’s role in transporting the crew. They also contended that the driller was fulfilling his employment duties by transporting the crew.
• Appellees (Employer/Insurer): Asserted that the accident did not arise out of or occur within the course of employment, as the workers’ travel was not an integral part of their job duties and did not meet the requirements of the traveling employee exception.

Legal Issues

• Whether the accident fell within the traveling employee exception to the going and coming rule under workers’ compensation law.
• Whether the driller was fulfilling the duties of his employment at the time of the accident.

Disposition

• The Court of Appeals affirmed the Workers’ Compensation Judge’s dismissal of the workers’ claims.

Reasons

Per Linda M. Vanzi, Judge (Celia Foy Castillo and Roderick T. Kennedy, JJ., concurring):

• The Court applied a whole record review standard, affirming the Workers’ Compensation Judge’s findings if supported by substantial evidence.
• The traveling employee exception requires that travel be an integral part of the job, such as requiring overnight stays or exposing workers to increased risks. The workers’ travel to the job site, though involving significant distances, was deemed a regular commute and not integral to their employment.
• The mobile nature of the drilling rig and the driller’s mileage reimbursement did not establish that travel was an integral part of the job. The reimbursement was found to merely defray vehicle costs, not to compensate for transportation as part of employment.
• The driller was not fulfilling employment duties at the time of the accident, as the employer did not require him to transport the crew. The evidence supported the finding that transportation was not a mandated duty.
• The Court concluded that substantial evidence supported the Workers’ Compensation Judge’s findings, and the claims were properly dismissed.