Johnson v. City of Albia
212 N.W. 419, 203 Iowa 1171 (1927)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
For the purposes of workers' compensation, an employment relationship terminates when an employee voluntarily quits and completes all required duties. The relationship is not extended merely by the employee returning to the premises the next day for a personal reason, and an injury sustained while voluntarily assisting a replacement without the employer's knowledge or authorization does not arise out of and in the course of the former employment.
Facts:
- Johnson was employed by the city as the engineer in charge of its pumping plant for seven years.
- On the morning of November 15, 1923, Johnson notified the city's waterworks committee that he would quit his job that evening.
- The city immediately hired a replacement, Seibert, to take over the position.
- Johnson worked until 7:15 PM on November 15, filled the water tanks, and then left the plant, informing Seibert where to find the key.
- Johnson left his personal tools at the plant, testifying he did so in case they were needed.
- On the morning of November 16, Johnson returned to the plant for the sole purpose of retrieving his tools and tending to other personal property.
- Upon arrival, Johnson found Seibert unable to start a pump that had a defective valve requiring a peculiar manipulation.
- At Seibert's request for assistance, Johnson entered the pump pit to help and was caught in some gearing, resulting in the loss of his left arm.
Procedural Posture:
- Johnson filed a claim for workers' compensation benefits with the Iowa Industrial Commissioner.
- The Industrial Commissioner found in favor of Johnson and awarded him compensation.
- The city (defendant) appealed the commissioner's decision to the state trial court.
- The trial court affirmed the Industrial Commissioner's order, ruling that the decision was based on a finding of fact and was therefore conclusive.
- The city (appellant) appealed the trial court's judgment to the Supreme Court of Iowa, with Johnson as the appellee.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does an injury, sustained by a person who had quit their job the previous day, arise out of and in the course of employment when they return to the former workplace solely to retrieve personal tools and are injured while voluntarily assisting their replacement at the replacement's request?
Opinions:
Majority - Faville, J.
No. The injury did not arise out of and in the course of employment because the employment relationship had completely terminated the previous day. Johnson's own testimony confirmed he had quit on November 15th. He returned to the premises on November 16th for a purely personal reason—to retrieve his tools—not to perform any work for the city. His assistance to the new employee, Seibert, was purely voluntary, undertaken without the knowledge, request, or authorization of any city official. This case is distinguishable from precedents where an employee was injured while following a direct order from the employer to complete a final task as part of the termination process. Furthermore, even if Seibert's request could be construed as creating a new employment relationship, it would be considered 'purely casual' and thus explicitly excluded from coverage under the workers' compensation statute.
Dissenting - Evans, C. J.
Yes. The injury did arise out of and in the course of employment because the employment relationship is deemed to continue for a reasonable time to perform duties incidental to its termination. The majority’s view is too restrictive and violates the spirit of the Workmen’s Compensation Act. A general custom for an outgoing engineer to assist their successor becomes an implied part of the employment contract. When Johnson encountered Seibert in trouble, he was fulfilling this implied duty. It is irrelevant that his initial purpose for returning was personal; upon seeing the need for assistance, his contractual duty was triggered, and in performing it, he was acting as an employee.
Analysis:
This decision narrowly defines the temporal scope of the employment relationship for workers' compensation purposes. It establishes that a voluntary resignation followed by the completion of all duties effectively severs the employer-employee relationship, limiting employer liability for subsequent events. The court created a clear distinction between an ex-employee returning to the worksite for a personal reason versus returning to fulfill a specific, employer-mandated, post-termination task. This precedent tightens the 'arising out of and in the course of employment' standard, making it more difficult for individuals to claim benefits for injuries sustained on a former employer's premises after their employment has formally ended.
