Brookhaven Baptist Church v. Workers' Compensation Appeal Board (Halvorson), 590 Pa. 282

Summary

The Pennsylvania Supreme Court considered whether a church member who was paid to cut grass was an employee under the Pennsylvania Workers’ Compensation Act. The Court held that he was a seasonal employee when performing paid grass-cutting work, but that trimming bushes was an unpaid trustee duty outside the scope of his employment. Because the fatal injury occurred while he was trimming bushes, the Court reversed the Commonwealth Court and denied workers’ compensation coverage.

Holdings

1. Halvorson was an employee under the Workers' Compensation Act because he was a natural person performing services for the Church for valuable consideration.
2. Halvorson's grass-cutting employment was not casual because it was regular, recurring, and continuous during the growing season; he was more properly characterized as a seasonal employee.
3. Maintaining the Church's grounds, including cutting the grass, was employment in the regular course of the Church's business.
4. Halvorson was not acting as an employee when injured because trimming the bushes was not part of his paid grass-cutting employment; he was acting as a Church trustee.

Questions Presented

1. Whether Halvorson was an employee of the Church under the Workers' Compensation Act when he was injured.
2. Whether the paid grass-cutting work was casual employment excluded from coverage by the Workers' Compensation Act.
3. Whether grass cutting constituted employment in the regular course of the Church's business.
4. Whether trimming the bushes was part of Halvorson's paid employment arrangement or instead an unpaid duty he performed as a Church trustee.

Disposition

reversed