AI Generated Opinion Summaries

Decision Information

Decision Content

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

Facts

  • Oilfield workers employed by Permian Drilling Corporation were involved in an automobile accident while traveling to their work site, resulting in one fatality and injuries to others. The workers argued that their injuries should be compensable under the Workers’ Compensation Act as they were "traveling employees" who encountered special hazards unique to their employment during their travel (paras 1-4).

Procedural History

  • Workers' Compensation Judge: Dismissed Workers' claims, concluding they were commuters and not traveling employees, thus their injuries were not compensable under the Act (para 5).
  • Court of Appeals: Upheld the WCJ’s dismissal, agreeing that substantial evidence supported the conclusion that the workers were not traveling employees when the accident occurred (para 6).

Parties' Submissions

  • Workers-Petitioners: Argued that they were traveling employees injured in the course of their employment, making their injuries compensable under the Act (para 5).
  • Employer-Insurer-Respondents: Supported the WCJ's conclusion that Workers were commuters, not traveling employees, and thus their injuries did not occur within the course and scope of their employment (para 6).

Legal Issues

  • Whether the injuries suffered by the Workers arose out of and in the course of their employment, rendering them "traveling employees" whose injuries are compensable under the Workers’ Compensation Act (para 1).

Disposition

  • The Supreme Court of New Mexico reversed the Court of Appeals’ memorandum opinion and remanded to the WCJ for further proceedings consistent with the Supreme Court's opinion that Workers’ injuries are compensable under the Act (para 22).

Reasons

  • The Supreme Court, with Justice Patricio M. Serna authoring the opinion, concluded that the Workers were traveling employees because their travel was mutually beneficial to both employees and employer, and they encountered special hazards unique to their employment while traveling. The Court found that the conditions of employment placed the Workers in a zone of special danger out of which their injuries arose, distinguishing their travel to the rigs from a commute. The Court emphasized that extensive travel is an integral part of the work of oil rig drillers and crew members, particularly for mobile rigs, and that the accident would not have occurred but for the required travel. The Court disagreed with the lower courts' conclusions, stating that substantial evidence supported the conclusion that Workers were injured in the course of their employment (paras 9-21).
 You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.