Cannon Cochran Management Services, Inc. v. FigueroaAnnotate this Case
In this appeal regarding the scope of the law-enforcement exception to the "going and coming rule" in workers' compensation matters the Supreme Court affirmed the order of the district court reversing the decision of the appeals officer, holding that the appeals officer's decision was arbitrary and capricious in light of the totality of the circumstances surrounding the officer's accident.
Plaintiff, a police officer, was struck by another vehicle during his drive home from work. Plaintiff filed a workers' compensation claim for the injuries he sustained in the accident. His claim was denied. On appeal, the appeals officer also denied the claim, concluding that Plaintiff's injury did not arise out of and in the course and scope of his employment. The district court granted Plaintiff's petition for judicial review and concluded that Plaintiff's accident indeed arose out of and in the course of his employment. The Supreme Court affirmed, holding (1) a court must look to the totality of the circumstances on a case-by-case basis in determining whether the law-enforcement exception to the going and coming rule applies; and (2) Plaintiff qualified for the law-enforcement exception under the totality of the circumstances test.