This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Two truck drivers employed by ABF Freight Systems, Inc. were injured during federally mandated rest breaks while traveling for work. One driver tore his biceps tendon while attempting to move a phone closer to his bed in a motel room. The other driver was fatally struck by a car while walking along a road near the motel during a break between assignments (paras 1-6).
Procedural History
- Workers' Compensation Judge: Awarded benefits to both employees under New Mexico's workers' compensation law (para 3).
Parties' Submissions
- Appellant (ABF Freight Systems, Inc.): Argued that the injuries were not compensable under workers' compensation law, asserting that the injuries did not arise out of or in the course of employment. ABF also contended that the union contract precluded liability as it did not control the employees' activities during rest breaks (paras 3, 14, 26).
- Appellees (Injured Worker and Estate of Deceased Worker): Claimed that the injuries were compensable under the "traveling-employee rule," as the injuries occurred during activities reasonably incidental to their employment while on mandatory rest breaks (paras 3, 14, 20).
Legal Issues
- Whether the injuries sustained by the employees during their rest breaks arose out of and in the course of their employment, making them compensable under New Mexico's workers' compensation law.
- Whether the "traveling-employee rule" applies to the circumstances of the injuries (paras 3, 7-13).
Disposition
- The Court of Appeals affirmed the Workers' Compensation Judge's decision to award benefits to both employees (para 30).
- The case was remanded to the Workers' Compensation Judge to award costs and attorney fees for the appeal (para 31).
Reasons
Per Robinson J. (Wechsler and Armijo JJ. concurring):
The Court applied the "traveling-employee rule," which provides continuous workers' compensation coverage for employees required to travel for work. This rule recognizes that traveling employees are exposed to hazards they would not face at home, and injuries arising from necessary activities like sleeping, eating, or exercising are generally compensable (paras 7-9).
In the case of the first worker, the injury occurred while he was in the motel room designated by the employer, performing an activity incidental to sleeping and preparing to resume work. The Court found this activity reasonable and foreseeable, and the injury arose out of the conditions of employment (paras 14-19).
In the case of the second worker, the fatal injury occurred during a walk taken while waiting for a truck assignment. The Court held that walking was a reasonable and foreseeable activity, and the employer benefited from having healthier, more refreshed drivers. The injury was therefore reasonably incidental to employment (paras 20-22).
The Court rejected ABF's arguments that the union contract precluded liability, emphasizing that the central question was whether the injuries were reasonably incidental to the employees' job activities. The union contract's allowance for personal freedom during rest breaks did not negate the applicability of the traveling-employee rule (paras 26-28).
The Court also dismissed ABF's reliance on cases involving non-traveling employees or factually dissimilar scenarios, finding them inapplicable to the traveling-employee context (paras 21, 25).