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Employee's Off-Duty Car-Crash Injuries Compensable: Court

The Kentucky Supreme Court said Adan Mandujano's car accident was compensable because he was performing the 'necessary and inevitable' act of returning from a trip that Gaines-Gentry and Eaton had requested him to take.

May 30, 2012
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The Kentucky Supreme Court says workers' compensation benefits should be paid to a horse groomer who was injured in a car accident, even though his employer said the man was off-duty when the crash occurred.

Adan Mandujano worked for Gaines-Gentry Thoroughbreds L.L.C. in Lexington, Kentucky, according to court records. He also showed horses for Lexington-based Eaton Sales, which court records show may have shared an owner with Gaines-Gentry.

In August 2007, Mandujano was asked by Eaton to travel to Saratoga Springs, New York, with several horses the company was selling on behalf of Gaines-Gentry. The companies did not provide Mandujano with return transportation, and he stayed in Saratoga Springs for several days to show horses with another firm.

Mandujano received a ride back to Kentucky with a friend, and suffered "skull fractures, cervical and lumbar spine injuries, and extensive dental injuries" in a car accident that occurred on the return trip.

Gaines-Gentry opposed Mandujano's following petition for workers' comp benefits, court records show, because it said the groomer's work duties ended once the company's horses were sold in Saratoga Springs. The company noted that Mandujano requested time off in order to work with other horse breeders after arriving in New York.

In a unanimous decision May 24, the Kentucky Supreme Court said Mandujano's car accident was compensable because he was performing the "necessary and inevitable" act of returning from a trip that Gaines-Gentry and Eaton had requested him to take.

"Although the claimant may have planned initially to travel to Saratoga for purely personal reasons and although he conducted personal business with Gaines Gentry's permission during at least part of his time at Saratoga, the purpose of his travel to Saratoga became work-related before he embarked on the journey," reads the ruling, which upheld a previous decision from an administrative law judge.

Sheena Harrison writes for Business Insurance, a sister publication of Workforce Management. To comment, email editors@workforce.com.

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