This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Worker, employed as a relief crew member for an oilfield drilling company, sustained an injury while commuting to a fixed drilling rig site located 40 miles from his home. The Worker argued that his role required extensive travel to various drilling sites, which he claimed made him a "traveling employee." However, at the time of the accident, the Worker was commuting daily to a single fixed worksite.
Procedural History
- Workers’ Compensation Administration, Victor S. Lopez, Workers’ Compensation Judge: Held in favor of the Worker, finding that he qualified as a "traveling employee" and was entitled to compensation for his injury.
Parties' Submissions
- Appellant (Employer/Insurer): Argued that the Worker was not a "traveling employee" as he commuted daily to a fixed worksite and was not provided transportation or travel allowances by the Employer. They contended that the Worker’s circumstances did not meet the legal criteria for a traveling employee.
- Appellee (Worker): Asserted that his role as a relief crew member required extensive travel to various drilling sites, exposing him to increased risks. He argued that this travel was integral to his job and conferred a benefit to the Employer, thus qualifying him as a "traveling employee".
Legal Issues
- Was the Worker a "traveling employee" under New Mexico law, thereby entitling him to compensation for his injury sustained during his commute?
Disposition
- The Court of Appeals reversed the Workers’ Compensation Judge’s decision, holding that the Worker was not a "traveling employee".
Reasons
Per Castillo J. (Wechsler and Kennedy JJ. concurring):
The Court found that the Worker did not meet the legal criteria for a "traveling employee." It emphasized that the Worker commuted daily to a single fixed worksite, which did not align with the definition of a traveling employee whose job requires travel between different work sites. The Court distinguished this case from precedents like Ramirez v. Dawson Production Partners, Inc. and Flores v. McKay Oil Corp., noting that the Worker was not on special assignment, was not provided transportation or travel allowances, and did not have to travel distances requiring overnight stays. The Court also rejected the Worker’s reliance on out-of-state cases, as New Mexico law sufficiently addressed the issue. The Court concluded that the Worker’s circumstances did not warrant a different interpretation under the law, and the Workers’ Compensation Judge’s legal conclusion was incorrect.