MGM MIRAGE v. Cotton, 121 Nev. 396

Summary

The Supreme Court of Nevada held that an employee injured on the employer's premises within a reasonable interval before or after work may be eligible for workers' compensation under a premises-related exception to the going-and-coming rule. Brenda Cotton injured her ankle in MGM Mirage's parking area approximately ten minutes before her shift, and the court concluded that her injury arose out of and in the course of employment. The court affirmed the award of workers' compensation benefits.

Holdings

1. Nevada recognizes a premises-related exception to the going-and-coming rule: an employee injured on the employer's premises while proceeding to or from work within a reasonable interval before or after work may be eligible for workers' compensation.
2. Cotton's injury arose out of and in the course of her employment because she was injured on MGM's premises within a reasonable time before work and established a causal connection between the injury and the workplace environment.
3. The appeals officer did not abuse her discretion or commit legal error by awarding Cotton workers' compensation benefits.

Questions Presented

1. Whether Nevada should recognize a premises-related or parking-lot exception to the going-and-coming rule for workers' compensation claims.
2. Whether Cotton's injury, sustained on her employer's premises approximately ten minutes before work while traversing a curb in the workplace environment, arose out of and in the course of her employment.
3. Whether the appeals officer abused her discretion or committed legal error by awarding Cotton workers' compensation benefits.

Disposition

affirmed