Lewis v. Workers' Compensation Appeals Board
542 P.2d 225, 15 Cal.3d 559, 125 Cal. Rptr. 353 (1975)
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Rule of Law:
An injury sustained by an employee on public property while traveling by a direct route between an employer-provided parking lot and the place of work is considered to arise out of and in the course of employment. Such an injury is compensable under workers' compensation law and is not barred by the 'going and coming' rule.
Facts:
- Grayce Ruth Lewis and her husband were both employees of the County of Sacramento.
- They customarily drove to work together and parked in a lot that the County leased exclusively for its employees' use.
- Mr. Lewis purchased a parking permit from the County, for which a monthly fee was deducted from his salary.
- The parking lot was located approximately three blocks from Lewis's office building.
- On the morning of the incident, Lewis walked from the parking lot toward her office along the most direct route.
- While crossing an intersection on a public street about one block from her office, Lewis slipped, fell, and sustained injuries.
Procedural Posture:
- Grayce Ruth Lewis filed a claim for workers' compensation benefits.
- The Workers’ Compensation Appeals Board denied her claim, finding that the 'going and coming' rule barred recovery.
- Lewis, as the applicant, sought review of the Board's decision before the Supreme Court of California.
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Issue:
Does the 'going and coming' rule bar workers' compensation for an injury an employee sustains on a public street while walking on a direct route from an employer-provided parking lot to their place of work?
Opinions:
Majority - Tobriner, J.
No. The going and coming rule does not bar recovery because the applicant's injury arose out of and in the course of her employment. An employee enters the course of employment upon arriving at the employer’s premises, which includes an employer-provided parking lot. The employment relationship is not terminated when the employee must cross public property while traveling on a direct route from the parking lot to the office. This travel falls within the 'reasonable margin of time and space' necessary for passing to and from the place where work is done. By providing a non-contiguous parking lot, the employer created a 'field of risk' that includes the necessary travel between the two portions of its premises. This conclusion aligns with the statutory mandate for liberal construction of the Workers’ Compensation Act and represents the majority view in other jurisdictions.
Analysis:
This decision significantly expands the 'premises' exception to the 'going and coming' rule in workers' compensation law. It establishes that an employer's premises can be fragmented, and the 'course of employment' extends to the necessary travel between these fragments, even over public areas. The ruling solidifies the 'field of risk' doctrine, holding employers responsible for hazards employees must encounter in the immediate vicinity of the workplace when that exposure is a direct result of the employer's logistical arrangements, such as providing off-site parking. This precedent makes it more difficult for employers to deny claims for injuries occurring just off-site but directly related to an employee's arrival at or departure from work facilities.
