This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A field deputy patrol officer employed by the Eddy County Sheriff's Department was required to be certified as a law enforcement officer within one year of assuming the position. After failing a pre-assessment running test for the certification course, the officer began a self-directed jogging program during off-duty hours to improve fitness. While jogging near his home, the officer suffered a heart attack (paras 2-5).
Procedural History
- Workers' Compensation Administration: Awarded compensation benefits to the worker.
Parties' Submissions
- Appellant (Employer/Insurer): Argued that the worker's injury did not arise out of or occur in the course of employment, as the jogging program was self-directed, conducted off-duty, and not mandated by the employer (paras 1, 4, and 14).
- Appellee (Worker): Contended that the jogging program was undertaken to meet the employer's certification requirements, which indirectly benefited the employer, and thus the injury should be compensable (paras 6-7 and 14).
Legal Issues
- Whether the worker's injury, sustained during a self-directed fitness program conducted off-duty, arose out of and in the course of employment.
Disposition
- The Court of Appeals reversed the award of benefits to the worker (para 15).
Reasons
Per Hartz J. (Donnelly and Bivins JJ. concurring):
The Court held that the worker's injury did not meet the statutory requirements of arising out of and occurring in the course of employment. The jogging program was self-directed, conducted off-duty, and not under the employer's control. The employer did not mandate or regulate the specific fitness activities, and the risk of injury was personal to the worker rather than employment-related. The Court relied on similar rulings from other jurisdictions, such as Haugen v. State Accident Insurance Fund and City of Los Angeles v. Workers' Compensation Appeals Board, which denied compensation for injuries sustained during voluntary, off-duty fitness activities. The Court emphasized that any expansion of coverage for such injuries would require legislative action, not judicial interpretation (paras 6-14).