In this case, the employee suffered admitted right upper extremity injuries in May of 2014. On June 26, 2014, he was on his day off. He left his residence and headed approximately 10 miles south to his ex-girlfriend’s parents’ home. After this stop, the employee proceeded approximately 10 miles north to his doctor. One block from the clinic, the employee was rear-ended. Immediately following the accident, the employee pulled his vehicle into the parking lot of the clinic he was headed to. The motor vehicle accident was alleged to have caused subsequent cervical spine symptoms.
A longstanding rule in Minnesota is that an employee is considered “in the course of [his/her] employment” while traveling to a doctor’s appointment for treatment of a work injury. This rule has, however, only been found to provide coverage where there is a sufficient connection between the travel and the employment. This case presented a novel factual situation, however, involving an employee on his day off with a secondary destination. Given the novelty, the Court was inevitably presented with a multitude of cases that did not quite match up. Without a sufficient factual analogue, the Court had to decide between two distinct rules used to assess the relationship between the trip/errand and the employment: the special errand test and the dual purpose trip test.
Under the “special errand” test, an employee who participates in an activity, on behalf of the employer, for a limited time or purpose remains in the course of their employment in the event of any injuries that should occur. The Court found the facts of this case too dissimilar and decided that this test was inapplicable. Specifically, the Court noted that the employee did not intend to begin or end his trip at the employer’s premises.
Under the alternative “dual purpose trip” test, a trip serving both a business and a personal purpose remains in the course of employment if “the trip involves service for the employer which would have called the trip to be taken by someone even if it has not coincided with the personal journey.” Here, the employee was going to his doctor for an admitted work injury. The Court implicitly held that a trip for treatment of an admitted work injury has a “business purpose” and that any deviation should be evaluated on the basis of whether it “obviate[s] the business purpose of the trip.” An example of such obviation, as provided by the Court, might involve a trip to an in-state provider that included a detour to Chicago. The Court was careful to observe, however, that providing for no detour was also too extreme.
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