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Injuries sustained by a Florida employee during an employer-sponsored bowling event arose out of and in the course of the employee’s employment since the event was not a “recreational activity” as defined in § 440.092(2), held a divided state appellate court. The majority observed that the bowling outing took place during regular work hours and those attending were fully paid for the time. The majority also noted that claimant’s supervisor testified that the purpose of the event was to improve morale and to discuss “some of our goals for the next year.” Under these circumstances, the majority said no reasonable person would have believed that the activity was not a required incident of employment.
Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is co-author of Larson’s Workers’ Compensation Law (LexisNexis).
LexisNexis Online Subscribers: Citations below link to Lexis Advance.
See Reynolds v. Anixter Power Sols., 2019 Fla. App. LEXIS 18265 (1st DCA, Dec. 10, 2019)
See generally Larson’s Workers’ Compensation Law, § 22.02.
Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law
For a more detailed discussion of the case, see
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