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Flight attendant’s shuttle bus injury is compensable


A flight attendant is entitled to workers compensation for the injury she sustained while riding a shuttle between an employee parking lot and an airport terminal, the Pennsylvania Supreme Court’s Western District in Pittsburgh held Wednesday.

In US Airways v. Workers Compensation Appeal Board, in a 6-0 decision, the justices affirmed a workers compensation judge’s decision that a flight attendant for was in the course and scope of her work when she was injured.

Betty Bockelman was a Philadelphia-based flight attendant working for Tempe, Arizona-based US Airways Inc. On Jan. 23, 2015, Ms. Bockelman was scheduled to work a round-trip flight from Philadelphia to Miami and parked in one of the two free employee parking lots. The lots are owned, operated and maintained by the City of Philadelphia for airport and airline employees, who must undergo background checks and fingerprinting to obtain the necessary security badges to enter the parking lot. Employers pay a one-time administrative fee to cover the cost of the background check and badge provided to employees.

After returning from Miami, Ms. Bockelman boarded the airport employee-only shuttle to the secured parking lot and while lifting her suitcase onto one of the shuttle’s racks, she slipped in a puddle, falling backward and crushing her left foot.

She filed a workers compensation claim alleging that she sustained disabling foot and ankle injuries as a result of the slip and fall, and sought total temporary disability benefits from Jan. 23, 2015, through April 19, 2015, when she returned to work. US Airways denied that Ms. Brockelman was in the course of her employment at the time of her injury.

Ms. Bockelman, a member of the Association of Flight Attendants, argued that the collective bargaining agreement between the union and the airline included a provision that the airline was responsible for providing free or reimbursed parking for flight attendants at their domicile airports.

A workers compensation judge granted Ms. Bockelman’s claim for workers compensation, holding that since she was injured taking a “specifically designated shuttle” that required employee identification for entry and exit right after her working flight, the injury arose in the course of her employment. US Airways appealed to the Pennsylvania Workers Compensation Appeal Board, which affirmed the compensation judge’s decision.

The airline appealed to the Pennsylvania Commonwealth Court, which also rejected US Airways’ arguments. The airline then filed a petition for allowance of appeal, which the Pennsylvania Supreme Court granted, to consider whether a worker who voluntarily uses an optional employee parking area remains in the course of her employment while traveling between that area and her typical workplace.

The state’s high court held that Ms. Bockelman’s injury was compensable, finding that “there are circumstances where an area can properly be designated as ‘on the employer’s premises’ within the meaning of the (Workers Compensation) Act even though the employer is not the legal owner of that area." 

Although US Airways argued that it does not instruct employees on where to park, the court held that the compensation judge correctly concluded that the lot in which Ms. Bockelman parked her vehicle was integral to US Airways’ business operations. The court held that US Airways was “clearly aware” that its workers used the employee parking lots at the airport since it paid for the badges and it would have been obligated under its collective bargaining agreement to reimburse flight attendants for the cost of airport parking if not for the airport employee lot.

The court, therefore, had “little difficulty concluding that the parking lot and shuttle were connected with, and thus integral to, US Airways’ business operations at the Philadelphia International Airport.”








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