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

• A worker at Curry County Adult Detention Center sustained injuries from horseplay on the premises. The worker, a booking specialist, engaged in a playful chase with a supervisory sergeant, resulting in a fall that broke her right ankle and fibula. This incident occurred during a slow work period, continuing a pattern of similar playful interactions between the two, which was part of a broader culture of horseplay at the detention center. Despite the detention center's policy against horseplay, there was no prior disciplinary action for such behavior. The worker initially provided a false account of the incident, fearing job loss and lack of compensation, which was later corrected upon review of surveillance footage.

Procedural History

• Workers’ Compensation Administration: The Workers' Compensation Judge (WCJ) awarded compensation to the worker, finding her injuries compensable under the Workers’ Compensation Act.

Parties' Submissions

• Worker-Appellee: Argued that the injuries were compensable under the Workers’ Compensation Act, emphasizing the culture of horseplay at the detention center and the lack of disciplinary action for such behavior.
• Employer/Insurer-Appellants: Contended that the worker's injuries did not arise out of and in the course of employment as required for compensability under the Workers’ Compensation Act, due to the nature of the horseplay.

Legal Issues

• Whether the worker's injuries, sustained during horseplay on the employer's premises, are compensable under the Workers’ Compensation Act.

Disposition

• The Workers’ Compensation Judge’s order awarding compensation to the worker was affirmed.

Reasons

• The Court of Appeals, per Judge Attrep, held that substantial evidence supported the WCJ's findings and concluded that the worker's injuries were compensable under the Workers’ Compensation Act. The court applied both the "New York rule" and the "course of employment test" to determine compensability, finding that the horseplay was a regular incident of employment and did not constitute a substantial deviation from employment. The court noted the culture of horseplay at the detention center, the lack of disciplinary action for such behavior, and the specific circumstances of the incident, including its occurrence during a slow work period and the worker's previous engagement in similar activities without reprimand. The court declined to establish a threshold notice requirement for employers regarding horseplay, emphasizing the Act's focus on the relationship between employment and the risk of injury rather than employer negligence or knowledge of specific activities.