Urbina v. Kindred Hospital-North Florida

Summary

The Florida First District Court of Appeal held that an employee injured in a vehicle collision while carrying out an employer-requested errand suffered an injury arising out of and in the course of employment. Because the employer and carrier presented no evidence of a pre-existing medical condition causing the accident, the claimant satisfied the major-contributing-cause requirement. The court reversed the denial of workers’ compensation benefits and remanded for entry of a consistent order.

Holdings

1. In the absence of evidence that Claimant had a pre-existing medical condition that contributed to the accident or injuries, Claimant satisfied the major contributing cause requirement by establishing that he was operating a motor vehicle at his employer's request, that an accident occurred, and that he was injured as a result.
2. An automobile accident and resulting injuries arise out of and in the course of employment when the employee is actively engaged in employer-directed work activities and is required to use an automobile to travel and perform those duties, even where the accident is alleged to have been caused by an idiopathic condition and no other identifiable risk or medical condition caused the accident or injuries.

Questions Presented

1. Whether the Judge of Compensation Claims improperly applied the major contributing cause standard when denying benefits in the absence of evidence of a competing pre-existing medical condition.
2. Whether an automobile accident occurring while an employee was actively performing an employer-directed errand arose out of and in the course of employment.

Disposition

reversed_and_remanded