Employer liable for snack break slip and fall

An Arkansas woman injured while walking to a snack vending machine is entitled to workers compensation benefits, an appeals court ruled last week.

The Arkansas court of appeals upheld a decision by the state's workers compensation commission that the injuries suffered by Joyce A. Wood arose “out of and in the course of” her employment and were therefore compensable.

In January 2014, Ms. Wood slipped and fell while working as a receptionist at Little Rock Centers for Youth and Families Inc. The fall occurred as she left her desk during a lull and resulted in a fractured pelvis.

An administrative law judge granted Ms. Wood benefits for her injuries, and the state's workers' compensation board affirmed the decision. The employer appealed, arguing that Ms. Wood was responsible for answering the telephone and greeting guests and that, because she had left her desk at the time she was injured, she could not have been performing employment services.

The appeals court sided with Ms. Wood, stating that while it is undisputed that Ms. Wood was “on the clock” at the time that she was injured, it is not uncommon for the employees to get snacks from the vending machine supplied by their employers and that after retrieving a snack, Ms. Wood would immediately resume her job duties because she could eat her snack at her desk.

“The Commission could reasonably conclude that Wood's briefly leaving her workstation to get a snack did not detract from her job duties, which benefited her employer, directly or indirectly,” the ruling states. “There is nothing in the record to suggest that Wood's actions were inconsistent with her employer's interest in advancing the work.”