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Meyer v. Workers' Comp. Appeals Bd. - 157 Cal. App. 3d 1036, 204 Cal. Rptr. 74 (1984)

Rule:

The test of reasonable expectancy of employment for determining whether injury during participation in off-duty activities is compensable consists of two elements: (1) whether the employee subjectively believes his or her participation in an activity is expected by the employer, and (2) whether that belief is objectively reasonable. Specific factors applied by the court to determine the reasonableness of the employee's belief includes employer involvement, benefit to the employer, and job related pressure to participate.

Facts:

Petitioner Christopher Meyer, a car salesman for respondent Elmore Motors, was injured in an automobile accident while en route to the Colorado River to spend the weekend with his supervisor and coworkers. Meyer thereafter presented a workers' compensation claim against Elmore Motors for injuries arising out of the accident. A workers' compensation judge found a compensable injury arising out of and in the course of Meyer's employment. Respondent Workers' Compensation Appeals Board ("Board") reversed. Meyer sought and was granted a writ of review, contending that under Cal. Lab. Code § 3600(a)(8), his injury was compensable as arising out of his employment.

Issue:

Was Meyer's injury compensable as a work-related injury?

Answer:

No.

Conclusion:

The court of appeals affirmed the Board's decision. The court applied a two-part test and determined that although Meyer subjectively believed that Elmore Motors required his participation in the outing, that belief was not reasonable. The evidence showed that Elmore Motors did not subsidize the outing, that the potential benefit to Elmore Motors was marginal, and that the pressure exerted to attend was almost nonexistent. The court found that even though the Board did not correctly apply the two-part test, the correct result was reached.

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