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Injury sustained during work bowling outing compensable


An ankle injury sustained by an employee during a company bowling event is compensable, an appellate court held on Tuesday.

In Reynolds v. Anixter Power Solutions, the Florida First District Court of Appeals in Tallahassee reversed and remanded in a 2-1 decision a Judge of Compensation Claims finding that denied the employee’s workers compensation claim.

Karen Reynolds was attending a bowling event with co-workers during her paid work shift when she injured her ankle. She filed a claim for workers compensation benefits, but the compensation judge concluded that the event was “recreational activity” and that her injury was therefore not compensable.

Ms. Reynolds appealed, and the appellate court reversed the judge’s decision.

The court noted that there was no dispute that the bowling event was during regular working hours, that the company paid employees to attend the event and that Ms. Reynolds was told she could not remain at work or take a vacation day rather than attend the event. Ms. Reynolds’ supervisor also testified that the event was being held to improve morale and discuss “some of our goals for the next year.” 

Although the company argued that each employee received an invite with an option to attend or decline, the court said that if an employer invites employees during work hours to discuss goals, “an employee is obligated to attend” and having an electronic option to decline is “insufficient to establish that participation in this event was voluntary.”

The appellate court held that although bowling may constitute a recreational activity, Ms. Reynolds’ involvement in the work outing was expressly required and “no reasonable person … would have believed that the activity was not a required incident of employment,” and therefore, her injuries were compensable.

The dissenting judge upheld the compensation judge’s decision, holding that Ms. Reynolds failed to present substantial evidence to show that the bowling event was required or that it provided a substantial benefit to her employer beyond improving employee health and morale.






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