LaPlante v. Taylor Box Co.
Docket: No. 84-206-Appeal
Court: Supreme Court of Rhode Island; December 23, 1986; Rhode Island; State Supreme Court
Sandra J. LaPlante appealed a decision by the Workers’ Compensation Appellate Commission which denied her compensation for injuries sustained in an automobile accident while employed as a driver for Taylor Box Company. The incident occurred on December 1, 1980, while she was returning from a delivery. After making a delivery in Providence, LaPlante deviated from her route to deliver a personal message at the United Methodist Care Center before continuing towards her employer's location in Warren. The central issue in the appeal was whether this personal deviation precluded her from receiving compensation for her injuries. The majority of compensation cases typically deny recovery in such scenarios, viewing the side trip as a personal deviation until completed, while a minority argue that once the employee begins returning to the employment route, they should be covered. The court noted various jurisdictions have differing views on when a deviation ends and employment resumes, emphasizing that if an employee demonstrates a clear return to their employer's business, they are again acting in the course of employment. The opinion referenced Larson's treatise on workers’ compensation, suggesting that once a personal errand is completed and the employee resumes their journey toward the business destination, they should be covered under workers' compensation laws. Instances where employees make brief personal stops during business trips can still qualify for compensation if the employee resumes their business duties afterward. Notable cases such as Dauphine v. Industrial Accident Commission and others support this principle. The key factor is whether, after completing a personal errand, the employee returns to a route reasonably related to their work, making any injuries sustained thereafter compensable. In the current case, the employee's deviation from her route was minimal. At the time of her injury, she was only a short distance away from her employer's location and would have returned within approximately fifteen to twenty minutes. The court determined that this route was effectively equivalent to the primary route and rejected the appellate commission's assertion that the employee should have taken a specific highway. Thus, the court concluded that the employee was acting within the course of her employment when the injury occurred. The appeal was upheld, reversing the appellate commission's final decree, and the case was sent back for a new decree consistent with this ruling. The court noted it could recognize obvious geographical facts without specific findings from the appellate commission regarding the distance to the injury site.