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Keywords

precedentappealworkers' compensationsustainedoverruled

workers' compensationsustained

Related Cases

Frett v. State Farm Employee Workers’ Compensation, 309 Ga. 44, 844 S.E.2d 749

Facts

Rochelle Frett, an insurance claims associate for State Farm, was injured when she slipped and fell in the breakroom during her scheduled lunch break. Frett had a mandatory, unpaid 45-minute lunch break and was free to leave the office or prepare her food in the breakroom. After microwaving her food, she slipped on water as she was exiting the breakroom. The State Board of Workers' Compensation denied her claim, stating her injury did not arise out of her employment because it occurred during a scheduled break.

At the time of the incident, Frett worked as an insurance claims associate for State Farm Insurance Companies ('State Farm'). Each workday, Frett had a mandatory, unpaid 45-minute lunch break.

Issue

Did Rochelle Frett's injury, sustained during a scheduled lunch break, arise out of and in the course of her employment, making her eligible for workers' compensation benefits?

Rule

An injury arises 'in the course of' employment when it occurs within the period of employment, at a place where the employee may be in performance of her duties, and while fulfilling or doing something incidental to those duties. An injury 'arises out of' employment when there is a causal connection between the conditions under which the employee must work and the resulting injury.

An injury arises 'in the course of' employment when it 'occurs within the period of the employment, at a place where the employee may be in performance of her duties and while she is fulfilling or doing something incidental to those duties.'

Analysis

The Supreme Court applied the rules regarding 'in the course of' and 'arising out of' employment to conclude that Frett's injury occurred on her employer's premises during her workday while she was preparing to eat lunch, an activity incidental to her employment. The Court found that the injury was causally connected to her work environment, as it occurred due to a hazard present in the breakroom. The Court overruled the precedent that injuries during scheduled breaks are not compensable, emphasizing that Frett was engaged in an employment-related activity at the time of her injury.

Applying these principles to this case, we conclude that Frett sustained an injury 'in the course of' her employment. It is undisputed that she was injured on the premises of her employer, in the middle of her workday, while preparing to eat lunch.

Conclusion

The Supreme Court of Georgia reversed the decision of the Court of Appeals and held that Frett's injury was compensable under the Workers' Compensation Act.

We now turn to whether her injury also 'arose out of' her employment.

Who won?

Rochelle Frett prevailed in the case because the Supreme Court found that her injury occurred in the course of her employment and arose out of her employment, thus entitling her to benefits.

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