Goins v. GKI/Employers

Summary

The Arizona Court of Appeals affirmed the denial of workers’ compensation benefits to Kenyatta Goins, who was injured when a handgun he was carrying for personal protection accidentally discharged at work. The court held that although the injury occurred in the course of employment, Goins failed to establish that it arose out of his employment because carrying the firearm was a personal choice unrelated to his job duties and the employer did not contribute to the risk.

Holdings

1. Goins's injury occurred in the course of his employment because it happened during working hours at the employer's premises while he was performing an employment duty.
2. Goins failed to establish that his injury arose out of his employment because the accidental discharge of his personally carried firearm resulted from a wholly personal, imported danger that was neither inherent in nor incidental to his employment and to which the employer did not contribute.
3. The injury was not properly analyzed as a mixed-risk injury because Goins did not identify a personal condition or personal cause that combined with an employment cause; the firearm was instead a personal danger imported onto the premises.

Questions Presented

1. Whether Goins's injury occurred in the course of his employment.
2. Whether Goins's injury arose out of his employment because the accidental discharge of a personally carried firearm resulted from a risk of employment, was incidental to his work duties, or was otherwise sufficiently connected to the employment to be compensable.
3. Whether the administrative law judge properly denied workers' compensation benefits under the applicable standard of review.

Disposition

affirmed