Meyer v. Workers' Compensation Appeals Board
204 Cal.Rptr. 74, 157 Cal. App. 3d 1036, 49 Cal. Comp. Cases 459 (1984)
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Rule of Law:
For an injury sustained during a voluntary, off-duty recreational or social activity to be compensable under workers' compensation, the employee's participation must be a "reasonable expectancy" of employment. This standard requires both that the employee subjectively believes participation is expected and that this belief is objectively reasonable based on factors like employer involvement, benefit, and pressure.
Facts:
- Christopher Meyer was a car salesman for Elmore Motors.
- Meyer's supervisor, Bob Rhoden, invited several salesmen to join him for a weekend at his personal property near the Colorado River.
- Rhoden told the invitees to bring their wives or dates for the social gathering.
- Meyer's sales had been slow that month, and he testified that he believed the gathering would be a 'pep rally' and feared he would be fired if he did not attend.
- Elmore Motors provided Meyer with a company car that he was permitted to use for personal travel.
- While driving the company car en route to the river after work, Meyer was seriously injured in a collision with a parked truck.
Procedural Posture:
- Christopher Meyer filed a claim for workers' compensation benefits.
- A workers' compensation judge, as the trier of fact, found Meyer's injury compensable as arising out of and in the course of his employment.
- Respondent Elmore Motors appealed to the Workers’ Compensation Appeals Board (Board).
- The Board reversed the judge's decision, finding the injury was not compensable.
- Meyer sought and was granted a writ of review from the Court of Appeal to challenge the Board's decision.
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Issue:
Does an injury sustained by an employee while traveling to a voluntary, informal weekend social gathering hosted by his supervisor arise out of and in the course of his employment under the "reasonable expectancy" exception to the general rule of noncompensability for off-duty activities?
Opinions:
Majority - Wallin, J.
No. The injury did not arise out of and in the course of employment because participation in the river trip was not a reasonable expectancy of the employment. The court applies the two-part 'reasonable expectancy' test from Ezzy v. Workers’ Comp. Appeals Bd. While Meyer met the first prong by subjectively believing his attendance was expected, his belief was not objectively reasonable. The court found that Elmore Motors' involvement was minimal, as the company did not subsidize or formally organize the informal gathering. The benefit to the employer was merely speculative, as any potential improvement in morale is too remote to justify compensability. Finally, the pressure on Meyer to attend was 'almost nonexistent,' as his sales slump was not unique and the supervisor's invitation was casual. Because Meyer's perception of compulsion was not objectively reasonable, the injury is not compensable under Labor Code section 3600.
Dissenting - Crosby, J.
The dissent does not directly answer the issue but argues the matter should be remanded for further proceedings. The majority resolves the case on a 'very sketchy record' after the Workers' Compensation Appeals Board applied the wrong legal standard. Key factual questions remain unanswered, such as whether the employer intended to underwrite the weekend, whether business meetings were planned, or whether Meyer was required to drive the company car as a condition of employment. The appropriate disposition is to remand the case to the board to apply the correct law from Ezzy and potentially take additional evidence to properly resolve whether the trip was a reasonable expectancy of employment.
Analysis:
This case refines the application of the 'reasonable expectancy' test for workers' compensation claims arising from off-duty social activities. By bifurcating the test into subjective and objective components, the court emphasizes that an employee's personal feelings of compulsion are insufficient for an injury to be compensable. The ruling clarifies that for an activity to be an objectively reasonable expectancy of employment, there must be concrete evidence of employer involvement, benefit, or pressure that goes beyond a supervisor's informal social invitation. This decision serves to narrow the scope of employer liability for injuries at such events, protecting employers from claims arising from purely social gatherings that have only a remote connection to the work.
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