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Worker Injured Getting Lunch From Her Car Not Acting in Scope of Employment

A security guard walked across a parking lot next to her employer’s property to reach her car parked on the street so she could get her lunch and move her car into the employer’s garage. She was injured when she slipped and fell on ice. Her workers’ comp claim was denied and she appealed. The Appeals Commission upheld the denial, saying her injury didn’t arise out of her employment. The “worker was performing a personal errand at the time of her slip and fall accident,” the fall happened on a parking lot not owned or controlled by her employer and she wasn’t required to cross that lot for work-related duties at the time she fell. Thus, the Commission concluded that her injury didn’t occur “at a time and place consistent with the obligations and expectations of employment” [Decision No. 2014-0050, [2014] CanLII 1744 (AB WCAC), Jan. 20, 2014].